Privacy Policy

The True Sales Company is owned by The Clear Path Company (UK) Ltd. We collect personal data in order to provide some of our services.

Our approach to privacy
The True Sales Company is a privacy conscious organisation and is strongly committed to protecting and
respecting your privacy. In most cases The True Sales Company is the controller of personal data processed as
described in this Privacy Policy for the purposes of the General Data Protection Regulation in Europe
(“GDPR”). This Policy describes what personal information we collect from you and how we process
your personal information when you use the The True Sales Companywebsite (“Website”) and our services. The True Sales Company will, from time to time, review its personal information collection, use and disclosure practices
to assure compliance with laws and regulations.

Whose personal data do we have
This Privacy Policy applies to personal data we process in relation to clients, training
attendees, suppliers, and website users.

Personal information we may collect from you
• We may collect personal information on your visits to our offices and Website including, but
not limited to, your IP address, browser, time-stamp, traffic data, location data, blogs,
content from surveys and contact forms and other communication data and the resources that
you access. Our collection of this personal information will make your visit to the Website
easier in the future as we will be able to suggest content that is relevant to you based on the
location you access the Website from, what content you access and how you interact with it.
• We may also collect information for marketing purposes and analysis, including information
on how you respond to email, sms text, phone and other marketing campaigns.
• We will collect any information you provide to us when you, for example, use
our referral scheme or send us a message. If you contact us, we will keep a record
of that correspondence.
• Examples of information we may request include but are not limited to: your First name, Last
name, Company name, Job title, Business email address, Telephone number, Job function,
Job level, Industry, Your location, Sector, Purpose of attendance.
• We use your personal information to send you direct marketing via email and other
communication means. You may opt-out of receiving future marketing communications at any
time by emailing admin@truesales.co.
• We may also store cookies as set out in more detail in our cookie policy

How we use your personal information
Your personal information will be collected and handled by us for the following purposes:
• To provide you with the training services you expect us to provide.
• To best tailor content and resources according to your preferences.
• To respond to your request or questions when you contact us.
• With your consent, we may also use your contact data for direct marketing to inform you
about services/products/events etc. that might be of interest to you (we will communicate by
email, telephone, mail and/or other communication methods).
• To send to you other information – such as The True Sales Company upcoming events or newsletters –
that may be of interest to you.
• To help us create, publish, and improve content most relevant to you.
• To ensure that the content provided through us is presented in the most effective manner for
you.
• To allow you to participate in interactive features of our Website, when you choose to do so.
• To further develop and improve the Website and systems to better serve you.
• To perform analytical research on our prospective client base, including the
content, and the services/products they are interested in.
• To transfer data to third parties (see below)
• Where necessary, to comply with any legal obligation; and
• We may also process your information to:
a. investigate or respond to incidents and complaints
b. comply with obligations and rights and cooperate with investigations carried
out by the police, government or regulators.

What does the law say about this?
Our use of your information as described above is permitted by applicable data protection law
because it is:
• necessary for our legitimate interests in pursuing the purposes set out above, and such
interests in each case not being overridden by your privacy interests;
• in some cases, necessary to meet our legal or regulatory responsibilities, such as disclosures
to authorities, regulators or government bodies; or
• in some cases, necessary for the performance of a task carried out in the public interest and,
when we use special categories of personal information, necessary for establishing,
exercising or defending legal claims or where the processing relates to personal information
manifestly in the public domain;
• in limited circumstances, processed with your consent which we obtain from you from time to
time, such as when you opt-in to receive marketing communications and news, via email and
other communication means.

Do you have to give us the personal information we ask for?
You are not obliged to provide your personal information to us when generally navigating our website,
however we cannot fulfil any specific requests for information or provide you with a tailored service
unless you do so.

Do we process information about you without any human intervention at all?
Yes, at times we may use automated systems/processes and automated decision-making to ensure
we give you a bespoke experience with us.

How long do you keep my personal information for?
We will keep your information for as long as you wish to receive our communications and thereafter
for the longer of the period required in order to meet our business, legal or regulatory responsibilities.
Typically, this is for 2 years.

Sharing with third parties
To facilitate our efficient use of your information, and to provide you with content and/or resources, or
to fulfil a request you make of us, we disclose your information to third parties. However, this
disclosure will only occur in the following circumstances:
• To suppliers, contractors and agents: from time to time we may engage or employ other
companies and individuals to perform functions on our behalf. Examples include the hosting
and/or maintaining of website content, or the provision of certain features contained on the
Website and the provision of marketing services.
• Such recipients will only have access to your personal information as required by them to
perform their functions and are not permitted to use such personal information for any other
purposes. These recipients will be subject to contractual confidentiality obligations.
• To government or law enforcement authorities if we determine in our sole discretion that we
are under a legal obligation to do so.

IP addresses and cookies
We collect information about your computer, including (where available) your IP address, operating
system and browser type, for system administration.

This is statistical data about our users’ browsing actions and patterns, and we will not use it in
isolation to identify you or any individual. If you provide us with personal data, such as your name, we
will then match your IP address and browsing history (for example) with that personal data.

For the same reason, we may obtain information about your general internet usage by using a cookie
file which is stored on your device. Cookies help us to improve the Website and to deliver better and
more personalised content.

If your computer is shared with other people, we advise that you do not select the ‘remember my
details’ option when that option is offered by the Website.

Where your personal information is stored and processed
As explained in the “Sharing with third parties” paragraph above, we share your personal information
with the following:
• Third party suppliers, contractors or agents: where we use a third-party supplier, contractor or
agent, your personal information remains under our control and we have controls in place to
ensure your personal information is adequately protected.

We endeavour to take all steps reasonably necessary to ensure that your personal information is
treated securely and in accordance with this Policy.

Do we transfer your data outside the European Union?
Your personal information can be transferred and processed in one or more other countries, in or
outside the European Union. We shall only transfer your data outside the EU to countries which the
European Commission believes offers an adequate level of protection to you, or where The True Sales Company has put in place appropriate safeguards to seek to preserve the privacy of your information.

Data Security
Although we will do our best to protect your personal information, you should be aware that the
transmission of information via the internet is not completely secure and we cannot guarantee the
security of your personal information transmitted to the Website or any third party; for this reason, any
transmission is at your own risk. We will use strict operational procedures and adequate, technical
and organisational security measures to prevent any unauthorised access, change, deletion or
transmission of this personal information.

Your rights. How you can access, correct and delete your personal information
Under applicable data protection laws, you have the following rights:
• Right to access and obtain a copy of your personal information: You are entitled to request
confirmation whether we process any of your personal information. Where this is the case,
you may have access to your personal information and to certain information about how it is
processed. In some cases, you can ask us to provide you with an electronic copy of your
information.
• Right to correct your personal information: If you can demonstrate that personal information
we hold about you is not correct, you can ask that this information is updated or otherwise
corrected.
• Right to be forgotten/have data deleted: In certain circumstances, you have the right to have
your personal data deleted. You may make such a request at any time and The True Sales Company will evaluate if your request should be granted, however this right is subject to any legal rights or
obligations we may have to retain data. For situations where, in accordance with the law, we
determine that your request to have your personal information deleted must be granted, Sales
Talent will do so without undue delay.

To exercise your rights, you can contact us at the following address: hello@truesales.co

To the extent our processing of your personal information is based on your consent, you also have
the right to withdraw your consent at any time.

Withdrawal of your consent will not affect the lawfulness of any processing based on your consent
before the receipt of such withdrawal.

You can also lodge a complaint about our processing of your personal information by emailing
hello@truesales.co or telephoning us on 020 3859 2000.

Marketing communications
We will only send marketing communications to you via email or other communication means where
you have consented that we may do so.

We will usually offer you a check box on the forms we use to collect your personal information where,
if you agree to receive marketing communications, you have to click the box. Where we send
marketing communications to you via email, you may opt out of receiving any further marketing communications.

You can also exercise your opt-out right at any time by contacting us at
hello@truesales.co and providing the following information: your name, your email address, a
contact telephone number, the marketing communications you would like to opt out of receiving.

Changes to this Policy
The terms of this Policy may change from time to time. We shall publish any material changes to this
Policy through appropriate notices either on our Website or contacting you using other communication
channels.

We welcome your comments concerning this Privacy Policy. If at any time you have questions or
concerns about The True Sales Company's Privacy Policy, or you believe that we have not adhered to our Policy,
please contact us: admin@truesales.co or call us on 020 3859 2000.

Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be
addressed to hello@truesales.co. You can request a copy of mechanisms relating to a specific
transfer of your personal information by contacting hello@truesales.co