Privacy Policy

Last updated: April 2025

Copyright Notice

Introduction

David Mandel & Associates, LLC, d/b/a Safe & Together Institute ("Safe & Together", "we", "us", or "our") respects the privacy of our users. This Privacy Policy explains how we collect, use, access, disclose, safeguard, store, and otherwise process the personal information of our users when you use our website ("Site"), our virtual academy ("Virtual Academy"), including our Perpetrator Pattern Mapping Tool ("PPMT"), our E-Store, access or attend our live or virtual sessions or events, and access or utilize any services, including subscription services ("Services").

For users in the United Kingdom, Safe & Together Institute is the data controller responsible for your personal data. We can be contacted at:

Safe & Together Institute
P.O. Box 745, Canton, CT 06019, USA
+001.44.860.319.0966
connect@safeandtogetherinstitute.com

Data Protection Framework

This Privacy Policy is designed to comply with relevant data protection legislation, including:

The UK General Data Protection Regulation (UK GDPR)
The Data Protection Act 2018
The Privacy and Electronic Communications Regulations (PECR)

Please Read Carefully

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access or use the Services. By accessing and utilizing the Services, you acknowledge and agree (i) to the terms of our Privacy Policy and any other applicable agreement that may be provided together with the Services; and (ii) that we have your permission to collect and process your personal information as described in this Privacy Policy. If you are agreeing to this Privacy Policy on behalf of an organization or entity, you represent and warrant that you are authorized to agree to this Privacy Policy on behalf of that organization or entity and to bind them to these provisions (in which case, the references to "you" and "your" in this Privacy Policy, except for in this sentence, refer collectively to you personally and to that organization or entity).

Changes to This Privacy Policy

We may need to make changes to this Privacy Policy as privacy laws change, our Services evolve, or we add or change service providers among other things. As a result, we reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last Updated" date of this Privacy Policy. We will also notify you via email should a material change occur. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on our website, and you waive the right to receive specific notice of each such change or modification. Your continued use of the Services following the posting of changes to these terms means you accept the updated Privacy Policy.

INFORMATION WE COLLECT

1. Information we may collect directly from you:

Personal Information that identifies you, such as your name; contact details including phone number, email address, and postal address; and when you buy something from our E-Store, register for an account to use the Virtual Academy or the PPMT; or register for a live or virtual event;
Account Registration Information, such as information provided by you when you register for an account to use the Services, including User ID, log-in details, security questions (and associated answers and passwords);
Professional or Employment-related information you provide, such as your current position, job title, business sector, geographic information, employer, or location, that you may provide in relation to the Services;
Marketing and Communications Data, including your marketing preferences or your interest in our Services; and,
Other personal information you submit to us through communications, purchase orders in our E-store, customer support exchanges, our "Contact Us" link, surveys, a promotion, reporting a problem, email, or otherwise.

Information you provide in the PPMT is discussed in more detail in the PPMT section below.

2. Information we may obtain about you based on your usage of the Services, your attendance at our sessions or events, from others, or by automated means:

Derivative Data, such as technical information about the Services, including device name and type, IP address, other setup data, usage, battery charge level, operating system, browser type, access times, pages viewed directly before and after accessing the Services, other interactions with the Services which are automatically collected and stored in log files;
Information We Obtain from Our Service Providers, such as personal contact details when you register for and utilize our Virtual Learning Academy, which is supported by a service provider, e.g., LearnWorlds, or order fulfillment information when you purchase something through our E-Store, which is supported by a payment processor, e.g., Stripe;
Data from our Social Media Pages, such as items, comments, feedback, or content posted on our social media pages;
Your Preferences and Interests, which you may identify in your profile or in your posts or comments in the Virtual Academy;
Audiovisual Information, including pictures you may upload to your profile on the Virtual Academy;
Geolocation Data, including the physical location of your device(s) through collection of data by using satellite, cell phone tower, or Wi-Fi signals;
Information We Obtain from Third Party Social Media Services, such as Facebook, LinkedIn, Twitter, Google, Instagram, and similar sites.
Images and Video Recordings, such as pictures and videos taken of attendees at our live or virtual events or sessions that you may attend.
Information We Collect from Publicly Available Sources, including registers, the internet, public authorities, previous employers, educational institutions, suppliers and vendors without obligations of confidentiality;
Commercial Information, such as history and records of the products and services you have obtained or purchased from us.
Marketing and Research Information, such as IP address, social media handle, or other online identifiers of a person, email address/mobile number if used for direct marketing and name and address, demographic data, (e.g., income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers); and
Cookies, web server logs, web beacons, and other technologies (See also Cookies Section below).
Information from your computer and mobile devices (where allowed by individual browsers and/or operating systems), such as:
- Unique device identifiers (e.g., Media Access Control (MAC) and Internet Protocol (IP) addresses);
- Browser type, version, language, and display/screen settings;
- Information about how you use and interact with our Site and App;
- Responses to advertisements on sites and mobile apps where we advertise;
- Log information, such as your search and voice-to-text queries in the mobile app;
- Search engine referrals;
- Geolocation information; and
- Social media preferences

LAWFUL BASIS FOR PROCESSING

Under the UK GDPR, we must have a lawful basis for processing your personal data. Depending on the specific processing activity, we may rely on one or more of the following lawful bases:

Contract: Processing necessary for the performance of a contract with you or to take steps at your request before entering into a contract.
Legitimate Interests: Processing necessary for our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms.
Consent: Where you have given clear consent for us to process your personal data for a specific purpose.
Legal Obligation: Processing necessary for compliance with a legal obligation to which we are subject.

The specific lawful basis for each type of processing is as follows:

For account management and providing our Services: Contract
For marketing activities: Consent or Legitimate Interests (depending on the relationship)
For security and fraud prevention: Legitimate Interests
For analytics and service improvements: Legitimate Interests
For legal compliance: Legal Obligation

HOW WE USE THE INFORMATION WE COLLECT

We use your personal and other information to:

Manage our relationship with you, including providing you with information regarding our Services and products, billing and order information, handling claims, troubleshooting, system maintenance, hosting and providing customer support services;
Fulfill your Orders, including orders and purchases made in our E-Store and completion of registrations for any live or virtual events;
Set up and manage your account and profile, including maintaining your use and/or subscription of any Services and contact you regarding your account;
Provide, develop, and improve the Services and products we may offer to you, including delivering our Services to you and for additional purposes that help us to develop and improve the quality of such Services and products (including as part of the development of any new products and services);
Facilitate communication between you and us;
Comply with a legal, regulatory or relevant industry standard obligation, including this Privacy Policy, intellectual property infringement, or enforcing our Terms of Service or other contracts you have entered into with us;
Protect against, identify, and prevent fraud or other criminal activity, claims, and other liabilities that we may notice based upon any activity on your account or your use of the Services;
Monitor your use of the Services as part of our operations in maintaining the Services, provided you understand we are not obligated to monitor your use of the Services;
Improve the security and other related system and network functions, including preventing misuse;
Perform analytics, including market and consumer research, anonymization and aggregation of personal information; and
Conduct marketing activities in accordance with applicable laws. For UK users, we will only send marketing communications with your explicit consent or where we have a legitimate interest to do so, and you have not opted out. You can opt-out of marketing communications at any time by using the unsubscribe link in any marketing materials you receive via email from us or by contacting us at the link provided on our website.

We may also use your information to contact you about our own goods and services as well as information pertaining to relevant educational and third-party offerings that may be pertinent to your sector, your profession, or your identified interests. If you do not want us to use your information in this way, please check the relevant box located on the registration form/adjust your user preferences in your account profile.

We do not use the information we have collected from you to enable us to display advertisements on our Site, in the Virtual Academy, and/or in the PPMT.

If you click on or otherwise interact with a website that links from our Services, the website and any advertiser thereon may assume that you meet its target criteria.

We do not have access to and cannot access the information you enter into the fillable forms in the PPMT and therefore do not use this information. This is discussed in more detail in the PPMT section below.

HOW WE SHARE YOUR INFORMATION

We share your personal information in the following limited situations with:

Our Service Providers, who provide some of our Services to you, including LearnWorlds, which supports the Virtual Academy, as well as services providers that may process, store, and provide us with technical assistance whereby we have entered into contracts with such service providers which include limitations on their use of certain of your information and only as necessary to provide these Services to us/you;
Third-Party Service Providers for Website and App Analytics, including automated technology to collect and analyze your information, including personal information to help us understand your use and optimize your customer experience (please see our section on Cookies and our separate Cookie Policy to learn more);
Professional Advisors and Governmental Authorities if we believe in good faith that disclosure, access, use or preservation of such information is necessary to (i) meet any applicable law, regulation, legal process or governmental request; (ii) enforce or investigate your compliance with the terms of any of our contracts or policies we have with you for potential violations; (iii) protect against physical, financial or other harm against the rights, safety or property of you, us, or any third party; and (iv) investigate fraud, technical, security or other operational issues; and
In connection with Corporate Transactions, meaning changes to our corporate structure due to the sale, transfer, merger or other reorganization of our company during which your personal information may be among the items sold or transferred.

We may share your non-personal information with:

Our Third Party Business Partners; and
Our Service Providers.

We do not have access to and cannot access information you enter into the fillable forms in the PPMT and therefore do not share this information. This is discussed in more detail in the PPMT section below.

INTERNATIONAL DATA TRANSFERS

Safe & Together is based in the United States, and we may transfer your personal data from the UK to the US and other countries outside the UK. When we transfer personal data outside the UK, we ensure that appropriate safeguards are in place to provide adequate protection for your data, which may include:

Standard Contractual Clauses approved by the UK government
Binding Corporate Rules where applicable
Where transfers are to countries deemed by the UK to provide an adequate level of protection

You can request further information about these safeguards by contacting us using the details provided at the beginning of this Privacy Policy.

YOUR RIGHTS UNDER UK DATA PROTECTION LAW

Under UK data protection law, you have several rights regarding your personal data:

Right to Access: You can request a copy of the personal data we hold about you.
Right to Rectification: You can ask us to correct inaccurate or incomplete data.
Right to Erasure: In certain circumstances, you can ask us to delete your personal data.
Right to Restrict Processing: You can ask us to restrict the processing of your data in certain circumstances.
Right to Data Portability: You can ask us to provide your data in a structured, commonly used, and machine-readable format for transfer to another controller.
Right to Object: You have the right to object to processing based on legitimate interests and direct marketing.
Rights Related to Automated Decision Making: You have rights related to automated decision making and profiling.

To exercise any of these rights, please contact us at ukprivacy@safeandtogetherinstitute.com. We will respond to your request within one month. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe your data has been processed unlawfully. The ICO can be contacted at https://ico.org.uk/make-a-complaint/.

THE PERPETRATOR PATTERN MAPPING TOOL (PPMT)

The PPMT offers you the opportunity to map a perpetrator's pattern using information from one or more of your cases. Should you choose to use it, the PPMT facilitates and supports your assessments, interventions, and outcomes of the case. The PPMT includes eight steps, each focusing on a different mapping activity. During each step, you will enter information about your case. For each of your active cases, you will be able to:

Save your work;
Edit your work;
Print your work; and
Delete your data once your case has been completed and printed.

In order to use and save your work, the PPMT requires your browser cookies to be turned on and for you to sign out of the PPMT.

We understand that the information that you provide in the fillable forms on the PPMT is confidential information, and in some cases, very sensitive information. The information you enter in the fillable forms on the PPMT is saved on your browser in a secure cookie. We do not have access to the information you save in the fillable forms on the PPMT. For purposes of clarity, we do not and cannot access the information you include in the fillable forms on the PPMT.

Given the nature of the information stored on your PPMT files on your browser, it is your responsibility to maintain the security of your account, your PPMT files, and your computer. Safe & Together cannot and will not be held responsible for unauthorized access to your PPMT files stored on your browser.

HOW WE SECURE YOUR INFORMATION

The security of your information is important to us. We practice industry standard security methods, including building defense in depth in our Services to address appropriate technical, administrative, electronic, and organizational safeguards to protect your information from unauthorized use, disclosure, and loss. Encryption technology, including current industry-standard encryption protocols, is used to protect personal information. We also use a variety of physical and infrastructure protection measures that comply with applicable regulations to protect and store your personal information. However, despite our efforts to secure your information, we cannot be responsible for the security of the information you transmit over networks that we do not control, including the Internet and wireless networks whether they are yours or others. You are responsible for keeping any user ID, password, and other log-in information secure. Please see the PPMT section regarding security of the information provided on the PPMT fillable forms.

DATA BREACH NOTIFICATION

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO without undue delay and within 72 hours after becoming aware of it, where feasible. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you without undue delay.

RETENTION OF YOUR PERSONAL DATA

We retain your personal information as follows:

The period during which we, or our service providers, store your personal information varies depending on the purpose for the processing:

For the provision of our Services and products, for so long as you are a customer or subscriber to the Services, and for 6 years thereafter to comply with tax and accounting requirements.
For marketing purposes, until you have opted out of receiving further direct marketing communications in accordance with applicable law.
For security-related data, generally up to 12 months from collection.
In all other cases, we store your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy or such retention period as required by law, following which time it is either anonymized (where permitted by applicable law), deleted or destroyed.

You can request specific information about retention periods for particular categories of data by contacting us.

Use of Cookies and other Data Collection Tools

Cookies are small text files placed on a user's computer, smartphone or tablet and are commonly used to collect personal information. Cookies are sent to your browser from a website and stored on your device. To enable our systems to recognize your browser or device and to provide and improve the Services, we use cookies and other data collection tools and similar technologies, such as pixels. These data collection tools measure and track customers' visits to and browsing activities as part of the Services and to compile statistical data.

This information assists us in marketing and managing our Services and enhancing your experience. For more information about cookies and how we use them, please read our Cookie Policy.

Cookie Consent: For UK users, we will only set non-essential cookies if you have given your explicit consent. You will be presented with a cookie banner when you first visit our site, allowing you to accept or decline non-essential cookies. You can change your cookie preferences at any time through our cookie management tool on the website.

As explained above, the PPMT requires cookies to be enabled on your browser. Should you disable cookies, you will not be able to use the PPMT in its full capacity.

Web Browser Settings

You can opt-out of our use of cookies to recall information about you by setting your browser not to accept cookies or to disable cookies. Most browsers also offer additional built-in tools to help you manage, control, and delete cookies, including cookies used for advertising. As explained above, the PPMT requires cookies to be enabled on your browser. Should you disable cookies, you will not be able to use the PPMT in its full capacity.

We support the development and implementation of a standard "do not track" browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized "do not track" feature is released, we will review the feature and determine whether the functionality may work with our Website accordingly.

CHILDREN'S DATA

You must be at least 18 years old to use the Services. Any use or access to the Services by individuals under the age of 18 is strictly prohibited and is a violation of this Privacy Policy. We do not knowingly process data relating to children under the age of 18. If we become aware that we hold data relating to a child under 18, we will take appropriate steps to delete this data.

CONTACT US

If you have any questions about this Privacy Policy or if you would like us to update the information we have about you, change your preferences, or exercise applicable data protection rights, please contact us:

Safe & Together Institute
P.O. Box 745, Canton, CT 06019, USA
Tel: +001.44.860.319.0966
connect@safeandtogetherinstitute.com

UK Data Protection Supervisory Authority
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113
Website: https://ico.org.uk