DATA PRIVACY NOTICE
Julie Johnson Ltd ("We") are committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller - A controller determines the purposes and means of processing personal data.
Data processor - A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
Julie Johnson Ltd is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: Acomb Drive, Wylam, Northumberland NE41. For all data matters contact Julie Johnson via email - email@example.com.
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- To maintain our own accounts and records
- Advertising, marketing and PR
You may give us information about you by filling in forms on our site, the-successclub.co.uk, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site/s; purchase our products or services; place an order on our site/s; request resources or marketing be sent to you; subscribe to our services or publications; participate in discussions or other social media functions on our site; enter a competition, promotion or survey; give us feedback; and when you report a problem with our site.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Direct interactions - name, address, e-mail address and phone number. Birthday, work/business details, financial and credit card information, and social media accounts.
- Automated technology or interactions - As you use our site/s we may automatically collect technical data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies.
- Third party or publicly available sources - technical data (analytics) from Google, Facebook, and Twitter. Identity and contact data from publicly available sources such as LinkedIn and Companies House.
5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
- Consent of the data subject - Optin form on our site/s for product or service and marketing communication
- Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
- Online purchase of product or service
- Offline purchase of product or service - face to face or via telephone/VOIP
- Processing necessary for compliance with a legal obligation - Notifying you of changes e.g. to privacy notice
- Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject
- Recovery of debts
- Requesting reviews or surveys
- Delivering relevant marketing and advertisin
- Using data analytics as a basis for improvements to site/s, products and services, customer relationships, internal processes and strategy
b) Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data:
- Processing relates to personal data manifestly made public by the data subject - Occasionally, relevant information relating to health or family circumstances given freely by potential client during a Success Breakthrough call, other personal call, email or text; or available online
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with IT and system administration service providers; professional advisers of legal, insurance, banking and accounting services; HMRC or other authorities or regulators who require reporting of processing activities in certain circumstances.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary in order to enable us to provide you with the services requested (including ongoing newsletter and information communications via email). Basic customer information (identity, and financial transaction data) is kept for a period of 6 years for tax and auditing purposes.
8. Providing us with your personal data
We require your personal data as it is a requirement necessary to enter into a contract.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent (optin) was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. Transfer of Data Abroad
All the personal data we hold about you will be processed by staff in the United Kingdom and, without your permission, we will not send your data to any third parties except those who directly assist us to provide the services stated above. These companies are:
Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
Teachable Inc, 16 W. 22nd Street, 6th Floor, New York, New York 10010, USA
Wave Financial Inc, 235 Carlaw Ave., Ste. 501, Toronto ON, M4M 2S1, Canada
You can obtain a copy of the safeguards and any other of Google’s data protection and privacy documentation by visiting https://privacy.google.com/businesses/compliance/.
You can obtain a copy of the safeguards and any other of Teachable’s data protection and privacy documentation by visiting https://www.teachable.com.
You can obtain a copy of the safeguards and any other of Wave’s data protection and privacy documentation by visiting https://my.waveapps.com/privacy/.
We take all reasonable steps to ensure that your personal data is processed securely.
11. Automated Decision Making
We do not use any automated decision making in our business.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
13. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Julie Johnson, firstname.lastname@example.org.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office, via email https://ico.org.uk/global/contact-us/email/, tel: 03031 231113, or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
Last updated 10th May 2018.