Webinar Privacy Policy

Neurodiverse Thinking (We/Our/Us) is a sole trader business based in the Isle of Man and owned by Emma Butler. Neurodiverse Thinking is committed to protecting your personal information and being clear about what information we hold about you and how we use it.

Neurodiverse Thinking holds webinars to provide support and training to parents and teachers in areas of Neurodiversity.

Zoom is the software used to deliver and manage webinars, allowing participants to log in and attend webinars at the time or view the webinar later.

Any personal information you submit when you register with Zoom or log in to Zoom to attend a webinar or view a webinar will be stored by, and accessible to, Zoom. Please only submit personal data which you are happy to have processed. Here is Zoom’s privacy policy: https://zoom.us/privacy

Neurodiverse Thinking is the ‘data controller’ of any personal information collected within scope of this privacy notice. Our Data Protection Officer (DPO) is the first point of contact for people whose information is processed. The contact details for our DPO are: Emma Butler, 21 Balleigh Court,Ramsey, Isle of Man Tel: 07624 381518 Email: emma@ndthinking.com

1 How we will use your information.

We can only use your personal information where we have a specific purpose or purposes for doing so. Neurodiverse Thinking holds webinars for parents, teachers, school staff and anyone interested in learning about neurodiversity.

We use Zoom as a tool to hold these webinars and to ensure that only those invited may log in to a webinar. To achieve the above aims, we will process your personal data for the following specific uses:

• to send out webinar invitations to individuals, who have signed up to receive our emails, and to confirm attendance for invited attendees only

• to provide participants with further information about the webinars

• to facilitate networking between participants at online events, attendees may be invited to submit via the registration form, question and answer (Q&A) or chat feature the following details: − name of provider or organisation − details of the networking opportunity they are interested in pursuing − generic email address that does not feature the name of a specific individual − permission to feature these details in the recording of the event. These details will be published for other attendees to view during the online event. They will also be included on PowerPoint slides to ensure the information is captured on the event recording. Recordings of online events may be hosted on the Neurodiverse Thinking YouTube channel and/or website

• to email a post webinar evaluation survey to ascertain how well the webinar was received; and to email a link to the recording of the webinar.

If we would like to use your personal information for a reason other than those purposes set out above, we will inform you of this before we start this processing, and we will provide you with further information about the new purpose/s.

2. Legal basis for using your personal information

Under data protection legislation, we require a legal basis to be able to process your personal information for the purposes set out above. In this case, the legal basis is:

• that processing the personal information is necessary for the purposes of Neurodiverse Thinking’s legitimate interests [GDPR Article 6(1)(f)].

3. Legitimate interests

We have a legitimate interest in collecting your personal information to ensure that Neurodiverse Thinking has the necessary information to host webinars effectively and to ensure that only invited individuals attend webinars or view webinars later.

Participant lists for our webinars

• We will hold a list of individuals who will be invited to attend webinars. Individuals will have the choice to attend the webinar, or to view the webinar later.

• You will be informed of our privacy policy when you log in to Zoom, and how we are processing your personal information.

4. Special category data

We do not collect special category data for Zoom webinars.

5. What personal information we will collect

For individuals who are logging in live, we will collect the following personal information:

• name

• email address

• How you heard about the event

• collecting device and location information

• IP address

• local IP (IP of device)

• network type

• type of microphone (for presenters)

• data centre

• collection type (joining and leaving webinar reasons and times).

For individuals who view the webinar later, we will collect the following personal information:

• name and email address

• collecting date of view.

6. With whom we share your personal information

As your personal information will be submitted by logging in to Zoom, any personal information you submit will be stored by, and accessible to Zoom. Zoom processes personal data in accordance with its own privacy policy: https://zoom.us/privacy Please only submit personal data, which you are happy to have processed, in accordance with Zoom’s privacy policy. We will not disclose your information to any other organisation except where required to do so as part of our functions or by law. Where your personal information will be stored Zoom is an American communications technology company based in California. Zoom confirm in their privacy notice that they are certified with the Privacy Shield, which provides organisations in the US with a way of showing that they provide adequate protection to the personal information of EU citizens. To learn more about the Privacy Shield, visit here: https://www.privacyshield.gov/list Your personal information will be stored in the European Union/EEA. This means that your personal information is protected under the GDPR. Zoom, in certain cases, will transfer data from the EU.

7. Your rights over your personal information

When your personal information is collected, you have certain rights in relation to that personal information that may be exercised.

You have the right to request:

• a copy of your personal information

• inaccurate personal information held about you is corrected

• your personal information is deleted

• processing of your personal information is restricted

• a copy of your information in a format that allows easy transfer ‘data portability’

• that you are not subjected to automated decision making or profiling (if these take place).

All these rights have certain limitations depending on the request and the purpose for which we are holding your personal information. Further information can be obtained by emailing emma@ndthinking.com.

8. How long we will hold your personal information

We are only able to retain a copy of your personal information for as long as it is needed for the purposes for which is was collected. If you choose to attend a webinar through Zoom, any personal data processed will be retained for as long as is considered necessary by Zoom, and in accordance with their privacy policy. Information on how to delete your Zoom account can be found on Zoom’s privacy notice.

We will keep data:

• to provide you with the services you have requested
• to comply with other law, including for the period demanded by our tax authorities
• to support a claim or defence in court

9 Use of cookies

Zoom’s Cookies are test files placed on your computer to collect standard internet log information and site visitor behaviour information. This information is used to track visitor use of the website and to complete statistical reports on website activity. Zoom use cookies to analyse trends, administer and track users’ movements during your visit to their website or use of their products, and gather information about you, where you access their website or products, how you use their products and services, and to provide you with information about Zoom products that you might be interested in. You can find out more from Zoom’s Cookie Policy: https://zoom.us/cookie-policy

10. Complaints about the use of your personal information

If you are unhappy with the way in which your personal information has been handled by Neurodiverse Thinking please contact us via our Data Protection Officer, emma@ndthinking.com, and we will try to resolve your issue informally. If we have not been able to resolve the issue to your satisfaction, you can make a complaint to the data protection authority. In the Isle of Man, this is the Isle of Man Information Commissioner. This can be done by writing to the following address:

First Floor
Prospect House
Douglas
Isle of Man
IM1 1ET

We would, however, appreciate the opportunity to talk to you about your concern before you approach the Information Commissioner.

11. Compliance with the law

Our privacy policy complies with the law in the Isle of Man, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’).

12. Review of this privacy policy

We shall update this privacy notice from time to time as necessary.