A.1. OUR GENERAL APPROACH TO PERSONAL DATA
We’re committed to protecting your privacy and honouring your legal rights to control how we use your personal data. We only collect and use personal data when we need to because you have asked us to do something for example, send you newsletters; so that we can reply to queries or complaints; to develop and manage our business relationships; to provide services to clients; to calculate payments to associates or Affiliates/Referrers; to meet our legal obligations. We strive to make sure the information we hold is accurate and up to date and is no more than we need to have.
A.2. CATEGORIES OF DATA
The types of information that we will be processing depend on the nature of our relationship with you. We may process information about you that you have yourself provided to us or published generally on the internet through social media or on other websites. In all cases, we will have what identifying and communication information that is relevant and that we can sensibly obtain: that is, your name, email address, employer or business name, job title or position, contact address, social media addresses, and we may also capture some of the information published by you in your social media output to the extent that it may be relevant to our interactions.
If you are or work for a prospect, we will aim to obtain and process information that is relevant to our building a business relationship with you and doing business together, which may relate to your business and your personal interests.
If we are processing information about you purely because we are providing services to others, please see Section D below. Please note that your rights may be subject to applicable exemptions.
If you have any questions or concerns about our use of your information, or how we have responded to any request about your personal data, please take it up in the first instance by emailing us at firstname.lastname@example.org
A.3. DOWNLOADS, NEWSLETTERS AND SERVICES
We monitor who opens what in our newsletter lists, and pre-set sequences of information we send you. We do this so we can see if content is popular and generate more of it, or if it is not read. There may be sub-routines that trigger if you click on links or articles. These are designed to offer you more information about things you are interested in. You can unsubscribe from these sequences at any time.
Existing Clients may receive emails about specific offers relating to things you have already purchased. You can unsubscribe from these at any time.
We use automations (little sequences of emails that start when you ask for something in particular) to send you the information you asked for and to administer services you have subscribed to. A lot of our onboarding for new services is by emails that send you tips and little videos on ‘how to’. You can unsubscribe from these at any time, but they don’t go on for that long and you might want to wait for all the information as most people find it useful.
We monitor who reads our mailing and automations, how many times, and which links you choose to use and read. We use this information to increase the content’s level of interest and help us improve what we send. You can remove your information from this monitoring by disabling cookies on your website browser before opening emails from us. From time to time, we contact individual email newsletter subscribers, but it is extremely rare.
We are not a hard sell or cold calling based organisation but prefer to build long-term relationships with satisfied and relaxed clients.
A.4. SOCIAL MEDIA
A.5. NO SALE OR EXCHANGE OF YOUR DATA
We do not sell or exchange your personal data with organisations who may want to sell you something or use your data for research or other purposes.
A.6. DATA LOCATION AND PLATFORMS
Like most small businesses, we do not have any tailor-made software – we use mainstream packages for everything from our Client records, to email, to accounting. This means that some of your data may be held in the EEA, and some may be held in services in the USA (with suitable data privacy shields) or elsewhere. We have picked mainstream suppliers with appropriate security standards.
A.7. WE MAY SHARE SOME OF YOUR DATA WITH THESE PEOPLE
We have an outsourced support team for our own business which may include Virtual Assistants, Web Designers, Accounting and more. They have limited access to your data, where the service they provide to us means they need it.
For example, if we invoice you, our Accountant needs to process the information in the invoice. Our team use our software to access any data they need. We do not permit copying or sharing by the team and actively monitor for any potential breaches. Your information/advice is held in the strictest confidence. We restrict who can export or download data that is held to a limited number of individuals who are authorised to back up data. If you want to know who is on our team, please email and ask us.
A.8. HOW LONG DO WE KEEP YOUR DATA FOR?
Your information will be kept for the length of time set out in our retention period. If you subscribed to a newsletter or updates list, you will remain on the list(s) you joined until you unsubscribe from that list.
A.9. WANT TO SEE WHAT WE HOLD ON YOU?
If you want to know what information we have about you (if any) email us at email@example.com and give us your name and email address(es). We may require you to confirm your identity before proceeding. Provided we can legitimately disclose the information to you (see Section D), we will happily do a search and send you screenshots of what we have.
A.10. WHAT ARE YOUR RIGHTS
You have the right to know what information we are collecting on you, and to amend it if it is inaccurate. If you feel for some reason we have information we should not be keeping, or it is out of date or otherwise wrong, please let us know and we will take appropriate action.
Most of the information we hold is not based on your individual consent but is based on our needing the information to run our business and provide our products and services. You have a "right to be forgotten" - but that does have some legal limits to it. If you want us to remove information about you, let us know. If you have been a Client, we may not be able to remove all data as we will have to ensure that we can continue to comply with legal, accounting, taxation and our insurer’s requirements.
A.11. OUR LEGAL BASIS FOR PROCESSING YOUR DATA
Signing onto our newsletter list is by your consent – and when you withdraw your consent we stop that processing of your data. Apart from that, the information we hold is based on our needing the information to run our business and provide our services – either so we can perform our contract with you, or because we have a legitimate business interest in processing your data. In a few situations we are processing personal data because we are under a legal obligation to do so. This principally relates to our business, accounting and tax records.
SECTION B: Prospects
Most of the information we process comes from you. We process it so we can reply to you, and when you contact us again we know what you asked before, what you were sent, and what you told us. Typically, we are collecting name, contact details, how we came across you, and background information from you or published by you on social media or freely accessible on the internet, on why you might be interested in our products or services or a relevant contact for our business.
If you sign up to a newsletter list, you will be sent what you asked for. We operate ‘double opt-in’ lists and you will need to reconfirm your subscription before anything is sent. You can unsubscribe at any time by clicking the unsubscribe button on any email. You are not automatically subscribed to any other lists but may be invited to join an appropriate one.
If we email you individually using our own email system or respond to an email sent to us at any of our business email addresses, a copy of that email will also be stored. If you make an enquiry via our website, we will keep details of that enquiry and response for our data retention period (Section 1, Table, above). We do not routinely keep special category data. To the extent we hold this, it was supplied or made publicly available by you.
If you'd like to discuss, query or request any information as pertained to the above, please do so by emailing us at firstname.lastname@example.org