Privacy Policy
This policy applies to MyRefund Ltd and its affiliated companies (collectively MyRefund Ltd)
This Privacy Policy was last updated on 26/07/2022.
MyRefund Ltd understands that your privacy is important to you and is committed to safeguarding the confidentiality and privacy of personal information entrusted to it.
This Privacy Policy describes how MyRefund Ltd handles and protects your personal information in connection with the hosting of this website, and the provision of its diverse business services, Courses, Private Consultancy, and Services (“Services”), as explained in more detail here: https://myrefund.com.co/.
Scope of this policy
This policy applies to personal information which is collected and/or used by MyRefund Ltd in its capacity as a controller as that term is defined in the EU General Data Protection Regulation (GDPR) and other similar laws. The contexts in which this might occur are explored under the section titled “When do we collect personal information?” below.
When we provide services to clients, we sometimes handle personal information as a processor. This means that we process the information solely on the instructions of our clients, who retain control of the information.
Therefore, if our use of your personal information is not covered by this policy, you may need to contact the client (and controller) on whose behalf the processing of your information is carried out.
The MyRefund Ltd entity responsible for your personal information will be the entity that originally collected information from or about you. If you have direct interaction with MyRefund Ltd (for example, you attend MyRefund Ltd courses), the identity of your controller may be disclosed to you in connection with that interaction. If we process your personal information in the course of providing our services to clients, your controller will be the T&H entity providing the services (assuming those services are provided as a controller, see above for an explanation). Please note that the contact details for all T&H entities in respect of data protection or privacy issues are the same, and areas set out below.
Who is your controller?
Your Acceptance
With respect to personal information collected over this and other MyRefund Ltd websites, your continued use of these websites constitutes your understanding of, and agreement to, the practices described in this Privacy Policy and elsewhere on the website as well as any subsequent updates.
When do we collect personal information?
We collect information about you if:
You use this (or any other MyRefund Ltd) website
You enquire about, or engage MyRefund Ltd to provide, its Services (either in a personal capacity, or as a representative for your employer or client)
You pay for services
The use of your personal information is reasonably necessary to provide our Services (in these circumstances, your personal information may be disclosed to us by our client who may, for example, be your employer or service provider, or we may obtain your personal information from a range of public or subscription sources, directly from you, or from your associates or persons known to you);
You apply for a position with MyRefund Ltd;
You attend a MyRefund Ltd hosted or sponsored courses or webinar;
You contact us with any other enquiry, complaint or notice.
What types of personal information are collected, and what do we use them for?
MyRefund Ltd collects your name, address, e-mail address, telephone number, and any other personally identifiable information which you voluntarily provide as “comments” when you submit an inquiry through the “Contact Us” tool. MyRefund Ltd also collects other background information about you in connection with career-related inquiries that you submit through its website.
MyRefund Ltd may also automatically collect personal information (through the use of cookies or similar technologies, including your IP address, device identifier, browsing patterns on its websites, clickstream data, and HTTP protocol elements) to ensure the effective operation of the website or in order to align the presentation of our services more closely to your requirements (for example, processing information about your broad geographic location to serve you with a local version of this website). This tracking information is stored in an anonymous, aggregated, and non-personal format, and is also used to understand and analyze trends, administer the websites, and learn about user behavior on the website.
Please refer to our Cookie Policy for a more detailed overview of how MyRefund Ltd uses cookies.
In certain instances, MyRefund Ltd may use IP addresses to help identify you when MyRefund Ltd feels, in its sole discretion, that it is necessary to enforce compliance with this Privacy Policy, to protect its services, websites, systems, information, employees, business partners, subsidiaries, affiliates, users, customers or others, or when required by law or for law enforcement purposes.
MyRefund Ltd’s Former, Current and Prospective Clients
If you submit an inquiry to MyRefund Ltd about our services (either over the website or by emailing, telephoning, or meeting with one of our colleagues), then we will process information such as your name, job title, and contact information in order to respond to your inquiry.
If you attend a MyRefund Ltd event or webinar, or if you associate with a MyRefund Ltd colleague at, for example, an industry event, then MyRefund Ltd may collect basic personal information, such as contact details, which you voluntarily provide (for example, by filling in a form or handing over a business card) in order to facilitate your participation in the event, and for the management of our relationship with you as an actual or prospective client.
If you or the organization you are associated with becomes a MyRefund Ltd client, then we may process your personal information in order to:
Carry out “Know Your Client” checks and screening prior to starting a new engagement (as well as basic contact information, this may mean processing compliance related information such as proof of your identity, information about your professional background, history of directorships and, in some circumstance, details of any criminal convictions or adverse media coverage).
Carry out background checks for the purposes of complying with anti-money laundering and terrorist financing laws.
Carry out client communication, service, billing and administration.
Deal with client complaints.
Administer claims.
Taking into account the applicable marketing laws, we also process personal information about our clients (former, current and prospective) in order to:
Send our clients newsletters, know-how, promotional material and other marketing communications
Invite our clients to events (and arrange and administer those events).
Performing Services for Our Clients
As discussed above, many of our services involve the processing of personal information. In the majority of cases, personal information is provided to us in strict confidence and is subject to restrictive undertakings regarding its use/disclosure.
Your Rights in Jurisdictions Covered by GDPR and similar Laws
If your personal information is processed by a MyRefund Ltd entity, then, subject to certain exemptions, and dependent on how and why we use it, you have certain rights in relation to your personal information.
We may ask you for additional information to confirm your identity before disclosing any personal information to you. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request.
We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Website Users
Right to Access
You have the right to access personal information which MyRefund Ltd holds pertaining to you, together with certain information about how and why your personal information is processed.
You have a right to request us to correct your personal information where it is inaccurate or out of date.
Right to Rectification
Right to be Forgotten
You have the right under certain circumstances to have your personal information erased. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the information.
You have the right to restrict the processing of your personal information, but only where:
Its accuracy is contested, to allow us to verify its accuracy.
The processing is unlawful, but you do not want it erased.
It is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims.
You have exercised the right to object, and verification of overriding grounds is pending.
Right to Restrict Processing
Right to Data Portability
You have the right to data portability, which requires us to provide personal information to you or another controller in a commonly used, machine-readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party. Please note that MyRefund Ltd rarely relies upon consent as a legal basis, and the performance of a contract basis will only be relevant to the extent that you, as an individual, are party to a contract with MyRefund Ltd or a client, and our use of your personal information is necessary for the performance of that contract.
You have the right to object to the processing of your personal information at any time, but only where that processing is based on our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to Object to Processing
Transfer Of Data
MyRefund Ltd is a global organization and may transfer certain personal information collected on its websites across geographical borders to MyRefund Ltd offices, personnel, or third parties located throughout the world. MyRefund Ltd may also store such information in a jurisdiction other than where you are based including outside of the European Economic Area (EEA).
Your information, including personal data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.
Please note that we transfer the data, including personal data, to the United Kingdom or European Union and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
MyRefund Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
MyRefund Ltd will not disclose your personal information to third parties other than as described in this Privacy Policy unless MyRefund Ltd has your permission or is required or permitted by law. MyRefund Ltd may share such information with its affiliates as necessary to carry out the purposes for which the information was supplied or collected. Similarly, third-party contractors, consultants, and/or vendors engaged by MyRefund Ltd to provide services may have access to your personal information. These third parties will be subject to their own data protection requirements providing the same or greater level of security provided by MyRefund Ltd and in most instances will also have entered into a written agreement with MyRefund Ltd which addresses the protection of your personal information.
MyRefund Ltd may also disclose your personal information for the purposes of:
Responding to requests from law enforcement agencies, regulators or courts, or to subpoenas, search warrants, or other legal requests.
The prevention and/or detection of crime.
Establishing legal rights or to investigate or pursue legal claims.
A merger, acquisition or corporate restructuring to which MyRefund Ltd is subject.
Preventing risk of harm to an individual.
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
Disclosure of Personal Information to Third Parties
Service Providers
We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), to provide the service on our behalf, to perform service-related tasks, or to assist us in analyzing how our service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Our service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
Links To Other Sites
Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Changes To This Privacy Policy
