How we respect and protect
Ros Conkie's Marketing Academy Privacy And Data Policy
By providing me with your data, you warrant that you are over 13 years of age.
I (Ros Conkie) am the data controller and I am responsible for your personal data. If you have any questions about this privacy notice, please contact me.
My full details are:
Full name of legal entity: Ros Conkie trading as Ros Conkie Marketing
My email address is firstname.lastname@example.org.
If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would be grateful if you would contact me in the first instance if you do have a complaint so I can try to resolve it for you.
It is very important that the information I hold about you is accurate and up to date. Please let me know if at any time your personal information changes by emailing me at email@example.com.
What data do I collect?
Personal data means any information capable of identifying an individual. It does not include anonymised data.
I may process certain types of personal data about you as follows:
- Communication Data that includes any communication that you send to me whether that be through the contact form on my website, through email, text, social media messaging, social media posting or any other communication that you send me. I process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. The lawful ground for this processing is my legitimate interests which in this case are to reply to communications sent to me, to keep records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. I process this data to supply the goods and/or services you have purchased and to keep records of such transactions. The lawful ground for this processing is the performance of a contract between you and me and/or taking steps at your request to enter into such a contract.
- User Data that includes data about how you use my website together with any data that you post for publication on my website. I process this data to operate my website and ensure relevant content is provided to you, to ensure the security of my website, to maintain back- ups of my website and/or databases and to enable publication and administration of my website, other online services and business. The lawful ground for this processing is my legitimate interests which in this case are to enable me to properly administer my website and my business.
- Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
- Marketing Data that includes data about your preferences in receiving marketing from me and my third parties and your communication preferences. I process this data to enable you to partake in my promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. The lawful ground for this processing is my legitimate interests which in this case are to study how customers use my products/services, to develop them, to grow my business and to decide our marketing strategy.
- I might use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising I serve you. The lawful ground for this processing is legitimate interests which is to grow my business. I may also use such data to send other marketing communications to you. The lawful ground for this processing is either consent or legitimate interests (namely to grow my business).
I may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where I review your Usage Data to work out the percentage of website users using a specific feature of my site. If I link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
Where I need to collect personal data by law, or under the terms of our contract and you don't provide me with that data when requested, I might not be able to perform the contract (for example, to deliver my services to you). If you don’t provide me with the requested data, I might have to cancel our contract but if I do, I'll notify you at the time.
I'll only use your personal data for the purposes for which it was collected or a reasonably compatible purpose if necessary. For more information on this please email me. In case I need to use your details for an unrelated new purpose I'll let you know and explain the legal grounds for processing.
I might process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision-making or any type of automated profiling.
I do not collect any Sensitive Data about you. Sensitive data refers to data that 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. I do not collect any information about criminal convictions and offences.
How I collect your personal information
I might receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
I might also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
The lawful ground for processing your personal data to send you marketing communications is either your consent or my legitimate interests (namely to grow my business).
Under the Privacy and Electronic Communications Regulations, I might send you marketing communications if (i) you made a purchase or asked for information from me about my products or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, I might send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from me at any time.
Before I share your personal data with any third party for their own marketing purposes I'll get your express consent.
You can ask me or third parties to stop sending you marketing communications at any time by following the opt-out links on any marketing communication sent to you or by emailing me at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
Disclosure of your personal data
I might have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities
- Third parties to whom we sell, transfer or merge parts of our business or our assets
I require all third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law. I only allow such third parties to process your personal data for specified purposes and in accordance with my instructions.
I am subject to the provisions of the General Data Protection Regulations (GDPR) that protect your personal data. Where I transfer your data to third parties outside of the EEA, I'll ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
- I might transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- If I use US-based providers that are part of EU-US Privacy Shield (such as Hubspot, Kartra and Stripe), I might transfer data to them, as they have equivalent safeguards in place; or
- Where I use certain service providers who are established outside of the EEA (such as Xero), I may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.
If none of the above safeguards is available, I may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
I have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. I also allow access to your personal data only to those employees and partners who need to know such data. They will only process your personal data on my instructions and they must keep it confidential.
I have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if I am legally required to.
I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding how long to keep the data I look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes, the law requires me to keep basic information about my customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers.
In some circumstances, I might anonymise your personal data for research or statistical purposes, in which case I might use this information indefinitely without further notice to you.
Your legal rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email me at firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I might charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or if you refuse to assist me with your request in these circumstances.
I might need to request specific information from you to help me confirm your identity and uphold 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. I might also contact you to ask you for further information in relation to your request to speed up my response.
I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you.
If you are not happy with any aspect of how I collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would be grateful if you would contact me first if you do have a complaint so that I can try to resolve it for you.
My website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections might allow third parties to collect or share data about you. I do not control these third-party websites and am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy notice of every website you visit.
Updates to this policy