We at Relational Frame Training Ltd. respect your right to privacy and comply with our obligations under the General Data Protection Regulations (GDPR; EU; 2018). By visiting this site and signing up as a customer, you are accepting the terms of this Privacy Statement.
Non-personal data consists of statistical and other site-user information collected in order to track site usage, and such things as the interests of casual visitors to the site (i.e., which pages they have viewed on our site), and the types of browsers used by site visitors. This non-personal data cannot be used to identify or contact you and will be stored on a secure server.
Personal data is gathered from customers when they sign up to purchase one of our products. This is essential because we need both contact details and payment details from customers. We also need age information from users in order to compare their performance to that of their peers and to therefore estimate intellectual gains in the user dashboard following training. If we do not have a more or less accurate age for you, you and we will not be able to see if your intellectual ability is above or below average, either before or after training. However, for added privacy we suggest that you feel free to provide an incorrect date of birth, but please keep it accurate to within one month. Please also use a non-identifiable user name for your account.
We also need some basic information regarding our customers in order that we can tailor our products to suit various customer needs. Thus, we hold data on site customers including; name, email address, and user IP addresses in circumstances where they have not been deleted, clipped or anonymised, billing and credit card information. We also ask for the date of birth of users, which is important for research purposes and for the proper feedback to users regarding gains in intellectual ability following training.
We are a scientific research company, and we conduct scientific research as part of the development of our training systems. We are relatively unique in that we publish our research in publically available scientific journals and allow the scientific community the opportunity to criticise and scrutinise our findings. In order to retain such high standards of scientific accountability, we need to publish our uses’ training patterns and gains in relational skills and we need to be able to link this information to their approximate age. However, we will always annonymise data so that the public could never link your intellectual gains to you. We will never publicise user names or exact dates of birth as provided by users. Under the 2018 GDPR, users have the right not to opt in during the sign-up process to having their data included in our research. They also have the right to change this choice at any stage thereafter. You can change your choice through your dashboard at any time.
All data is held on secure servers. We currently use the USA-based DigitalOcean.net as our server provider. They are fully complaint with GDPR and the details of their security and privacy measures can be found here. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet. No data transmission over the internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your personal data within the letter and spirit of the GDPR.
You may inform us of any changes in your personal data, and in accordance with our obligations under the GDPR we will update or delete your personal data accordingly. To find out what personal data we hold on you or to have your personal data updated, amended or removed from our database, please contact us at: firstname.lastname@example.org.
Minimum Age of Account Holders
Under EU data protection legislation, a child under 13 years of age is not permitted to hold an online account containing personal or identifiable data. For this reason, users must confirm that they are 13 years of age or older when they sign up for an account. If you are under 13 years of age you MUST have a legal guardian (e.g., parent) create the account on your behalf. They can manage the account and allow you access it as they see fit.
Disclosure of Information to Third Parties
We may provide non-personal data to third parties, where such information is combined with similar information of other users of our site. For example, we might inform third parties regarding the number of unique users who visit our site, the demographic breakdown of our community of site users, or the activities that visitors to our site engage in while on our site. The third parties to whom we may provide this information may include, potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties.
We will not disclose any personal data to third parties unless you have consented to this disclosure or unless the third party is required to fulfil your order, such as a product purchase (in such circumstances, the third party is bound by similar data protection requirements). In these cases, we will disclose only that personal data absolutely required (e.g., contact and payment details) in order for a third party (e.g., an on-line payment company or credit card company) to carry out the duty you requested (e.g., purchase a product). Of course, we may be required to disclose personal information to authorities in order to comply with an applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
Duration of Data Retention
Because our training is ongoing and can be revisited at any time, we will keep your account open indefinitely so long as it is occasionally used. If the account is unused for two years we will send a notice to you of our intention to delete it and giving you a chance to activate it again by logging in. If you fail to do so within four weeks, the account will be deleted.
Sale of Business or Bankruptcy
We reserve the right to transfer information (including your personal data) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of the Website Privacy Statement and provided that the third party only uses your personal data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out. In the event of bankruptcy, all accounts will be deleted permanently and no record will be kept of your account with us.
Changes to the Website Privacy Statement
Any changes to this Website Privacy Statement will be posted on this site so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use personal data in a manner significantly different from that stated in this Website Privacy Statement, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your information in the new manner.