⚖️ Legal stuff

Privacy policy.

Published on: Wed 1 Nov 2023
Last updated: Mon 22 Jan 2024

Welcome to FuturFaith Limited’s privacy policy. FuturFaith Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tells you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how FuturFaith Limited collects and processes your personal data through your use of this website or the use of our services, including any data you may provide through this website when you apply or are registered as a student of FuturFaith Ministry.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

FuturFaith Limited is the controller and responsible for your personal data (collectively referred to as “FuturFaith”, "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

- Full name of legal entity: FuturFaith Limited

- Email address: support@futurfaith.com

- Postal address: Homestead House, 22 Seatown Place, Dundalk, Louth, Ireland (A91 H365)

You have the right to make a complaint at any time to the Data Protection Commissioner (DPC), the Irish regulator for data protection issues https://www.dataprotection.ie. We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 22 January 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

- Identity Data includes first name, last name, profile picture, photograph and video recordings, social
media details, username or similar identifier, title/role, date of birth and gender.

- Contact Data includes address, phone number, number, email address and telephone
numbers.

- Financial Data includes payment card details.

- Technical Data includes internet protocol (IP) address, your login data, browser type and version,
time zone setting and location, browser plug-in types and versions, operating system and platform,
and other technology on the devices you use to access this website.

- Student Data includes your username and password, details regarding your participation in our
course, biography, organisation, learning data (including achievements and rankings), your interests,
course material, assignments (including video recordings), preferences, feedback and survey
responses.

- Usage Data includes information about how you use our website and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

- Direct interactions. You may give us your Identity, Contact, Student and Financial Data by filling in
forms or by corresponding with us by post, phone, email or otherwise. This includes personal data
you provide when you:

• apply to become a student;

• create a profile on our website;

• submit assignments as part of our course for grading;

• subscribe to our service or publications;

• give us feedback or contact us.

- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookie and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://www.futurfaith.com/cookies for further details.

- Third parties or publicly available sources. We may receive personal data about you from various
third parties and public sources such as Technical Data from the following parties:

(a) the Register of Solemnisers

(b) analytics providers such as Google;

(c) social media pages such as Facebook, LinkedIn , and Instagram;

(d) advertising networks; and

(e) search information providers.

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

- Where we need to perform the contract we are about to enter into or have entered into with you.

- Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests.

- Where we need to comply with a legal obligation.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a student or user

(a) Identity
(b) Contact

Performance of a contract with you

To register you as a student or userTo manage our relationship with you which will include:
(a) Providing course material to you
(b) Notifying you about changes to our terms or privacy policy

(a) Identity
(b) Contact
(c) Student

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how students use our services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, services, customer relationships and experiences

(a) Technical
(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about our services that may be of interest to you

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Student

Necessary for our legitimate interests (to develop our products/services and grow our business)

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.futurfaith.com/cookies.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” section above.

• External Third Parties as set out in the [Glossary]Glossary Section (see further below).

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

Most of our External Third Parties and service providers are based in Ireland but sometimes we may need to store and process your personal data outside of Ireland and the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

● We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

● Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Ireland.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements. In some circumstances you can ask us to delete your data: see your legal rights below in the Glossary section below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to support@futurfaith.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers based who provide IT and system administration services.

• 360Learning SaaS Learning Management System for the purposes of delivering our course.

• Professional advisers including solicitors, bankers, auditors and insurers based in Ireland who provide consultancy, banking, legal, insurance and accounting services.

• The Revenue Commissioners, regulators and other authorities based in Ireland.

YOUR LEGAL RIGHTS

Under certain circumstances, by law you have the right to:

A. Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.

B. Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. As part of our response to any data subject access request, we are also required to provide you with certain information about our processing of those personal data.

C. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

D. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

E. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

F. Object to automated decision-making including profiling, that is not to be the subject of any automated decision-making by us using your personal information or profiling of you.

G. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

H. Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.

I. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Some of the above rights may be subject to conditions or restrictions, depending on the particular circumstances. However, when responding to any request that you make to exercise your rights, we will inform

you about any conditions or restrictions and will explain how these may affect our ability to fully respond to your request.

If you would like to exercise any of these rights, please contact FuturFaith at support@futurfaith.com