PRIVACY AND COOKIES POLICY

Version number: V1
Effective date: 2019-05-10

1. Who are we?
1.1 We are Cognitive Behavioural Directory Ltd trading as “The Cognitive Behavioural Directory”. For privacy queries, you can contact us at privacy@cognitivebehaviouraldirectory.com. Other contact details are on our website.

2. What’s the point of this policy?
2.1 It tells you what to expect when we collect your personal information via our website. Please only use our service if you agree with this policy.

2.2 Generally, the policy covers only information provided to us. If you give personal information to other people, such as advertisers, payment providers or other websites, please check their privacy policies.

3. Might the policy change?
3.1 Yes. Please check it whenever you visit our website. We will assume you agree to the new version of the policy if you use the site after its effective date. We may also notify you of any changes by email or in-service message.

4. What do we collect?
4.1 Information which you upload to our service or otherwise give us such as:
• your name and contact details;
• other information provided when you register with us such as photographs and professional information;
• details about your transactions on our service;
• information included in your advertisement / listing, posts, reviews or which you otherwise provide for display on our service or which you include in messages sent via our service;
• contact or other information which you give or allow us to use for newsletters or other marketing; and
• your communications with us.

4.2 Automated information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the site from which you arrived at our service, details of your activity with date / time stamps including pages you visited and your searches / transactions.

4.3 Information about your location.

4.4 The following information about you may be provided to us by other people:
• Limited billing information sent to us by our payment provider for verification purposes e.g., your name, email address and billing / delivery addresses.
• If you log in via social media websites: Your name, email address and profile photo.

5. What’s our reason / legal basis for collecting the information?
5.1 Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract, e.g., send service messages, process payments and fulfil orders. This applies to initial enquiries and to contact and transaction details as well as to location information and advertisements / listings, posts, reviews and other information which you provide for public display on our service.

5.2 Because it’s in our “legitimate interests”, e.g., to manage and improve our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to automated usage data.

5.3 Because you’ve agreed by ticking the consent box on our website. This applies to contact or other information which you give or allow us to use for newsletters or other marketing. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.

6. How long do we keep personal information?
6.1 Until your account is closed or our contract with you has otherwise ended.

6.2 We may hold on to some of your information for longer (typically up to six years) if reasonably needed for legal, regulatory or tax reasons, deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions.

6.3 We will keep your information which we use only for newsletters or other marketing until you tell us to stop sending you such messages.

7. To whom do we send or make available your personal information?
7.1 To other people who supply us with a service, e.g. website hosts, payment providers, and businesses which help us send communications or monitor our website and which provide us with e-commerce, analytics and other IT services.

7.2 To other users of our service, if you include personal information in an advertisement / listing, post, review or other public action on our service.

7.3 To credit reference agencies, regulators and the police and other law enforcement authorities to help deal with fraud and abuse and/or comply with legal requirements.

7.4 To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.

7.5 To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.

8. Do we send your information outside the European Union?
8.1 Your personal information which we collect is stored within the EU and is not transferred to any third countries except as follows.

8.2 Your personal information may be transferred to the US by the following companies certified under the EU-US Privacy Shield Framework, which provides certain safeguards for your personal information: Google (analytics / advertising), Facebook (advertising / social media), Automattic Inc (spam protection), PayPal (payments), Twitter (social media), LinkedIn (social media), Instagram (social media), Get Response (email management), Nextend (social media login), WordPress (webforms).

9. What rights do you have?
9.1 If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g. marketing).

9.2 You may also have the right to object to use of your personal information in certain circumstances.

9.3 If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO).

9.4 For more information about your rights, visit the ICO’s website: www.ico.org.uk.

10. What about cookies?
10.1 We and/or other companies use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your web browser. Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Some are session temporary “session” cookies that remain in the cookie file of your browser only until your browser is closed. Whereas persistent cookies stay for longer (depending on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete existing cookies, visit: www.allaboutcookies.org. Our site’s functionality will be limited if you configure your browser to reject cookies.

10.2 We ourselves place the following types of cookies:

Type of cookies Purpose
Logged-in status Assess whether you are logged in to our site
“Remember me” Remember you and speed up your login when you return to our site
Log In cookies Allow login through social media websites
Authentication Identify and authenticate you to help you move easily through the site
Preferences Store information about the preferences you’ve selected (eg favourites, currency, wishlists) and personalise the site
Shopping cart Remember contents of your cart and related preferences
Security Provide security-related features to protect our site, for example to help stop fraudulent logins
Cookie notice Store your response to our cookie notice

10.3 Companies which provide us with a service also place cookies. Some of these cookies (e.g. from Google) may involve certain information, such as your IP address and web address of the page you’re visiting, being sent to the company concerned. Below is a summary of the kinds of cookies used together with details about who places them and where you can go to get more information and to opt out (where possible):

• Analytics cookies: These kinds of cookies recognise and count the number of website visitors as well as providing other information about the visit such as duration, route through the website and where the visitor came from. This information helps us to improve the way our website works, for example by making sure users find what they need easily. These cookies are provided by:

• Google Analytics (“GA”). More:
– general information about the types of cookies placed by Google including analytics
– a technical explanation of GA cookies
– Google’s use of its partners’ data including how to control information collected by Google
– how to specifically opt out from GA cookies
– Google’s privacy policy

• Advertising cookies: These kinds of cookies are typically used to personalise ads on this or other sites based on your use of our site, to measure ad effectiveness (for example, how often you click on or view ads and whether you go on to buy something from the advertiser) and to stop you being shown the same ad repeatedly. These cookies are provided by:

• Google (including Analytics Ad Features / AdSense / Doubleclick)
– general information about the types of cookies placed by Google including advertising
– how Google uses cookies and other technologies in advertising including how to opt out of advertising cookies (this explains how ad personalisation works)
– Google’s use of its partners’ data including how to control information collected by Google
– Google’s privacy policy

• Facebook (including “Facebook Pixel”)
– Facebook’s cookies policy (see especially under “Advertising, recommendations, insights and measurement”) including how to control Facebook’s use of cookies
– Facebook’s privacy policy

Note that there are various places where you can go to opt out of many companies’ advertising cookies in one go including some or all of the above:
– www.networkadvertising.org/choices
– http://www.youronlinechoices.com/
– http://optout.aboutads.info

• Social media cookies: These kinds of cookies are placed by social media companies when you use their features on another site, for example if you play embedded audio or video, click a Facebook “like” or sent a tweet. These features may involve the relevant companies using cookies to collect information relating to your visit to our website or your interaction with their services or otherwise. Click the following links for further information including how to opt out where this is possible: Facebook, Twitter, LinkedIn, Pinterest, Instagram, YouTube

• Payment provider cookies: Our payment provider may place cookies if you use their payment services on our site:
– Paypal’s privacy policy

• Third party log-in cookies: If you log in through a third party website, that website will place its own cookies on your computer. See above for links to the privacy / cookies policies of Facebook, Instagram, LinkedIn, Google and Twitter.