1. Introduction

Philip Budd (Business Growth East Anglia Ltd) is committed to protecting the privacy and security of your personal information. We take care to protect the privacy of our customers that communicate with us, over the phone, through our website, social media platforms and in person.

This privacy policy will inform you as to how we collect your personal data, what we do with your information, what we do to keep it secure as well as the rights and choices you have over your personal information.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Throughout this document we refer to Data Protection Legislation which means the Data Protection Act 2018 which incorporates the General Data Protection Regulation (GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the General Data Protection Regulation which is the governing legislation that regulates data protection across the EEA. This includes any replacement legislation coming into effect from time to time.

We have appointed a Data Protection Lead (DPL) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact them by using the details set out below.

Philip Budd (Business Growth East Anglia Ltd)

philipbudd@actioncoach.com

Freedom House, 5 Abbeyfields, IP33 1AQ 07585784183

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2. The information we collect

We only collect information that we know we will genuinely use and in accordance with the Data Protection Legislation.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The type of information that we will collect on you, and you voluntarily provide to us on this website, over the phone, via forms, service delivery or face to face includes:

  • Your Name
  • Address
  • Telephone number(s)
  • Email address
  • Survey responses
  • IP address
  • Cookies

We may, in further dealings with you, extend this information to include your purchases, services used, and subscriptions, records of conversations and agreements and payment transactions etc. You are under no statutory or contractual requirement or obligation to provide us with your personal information; however, we require at least the information above in order for us to deal with you as a prospect, customer or service user in an efficient and effective manner.

Marketing and Communications Data includes your preferences in receiving marketing from us including newsletters and email communications.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.

This website and our service is not intended for children and we do not knowingly collect data relating to children.

Cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. Except for essential cookies, all cookies will expire after 6 months.

For more information about the cookies we use on act, please see the cookie notice here Remarketing

We also use Facebook Tools and Clickfunnels as part of our service. You will only be retargeted if you previously accepted the terms of the platform and consented to remarketing.

Facebook remarketing service is provided by Facebook Inc that include the use of cookies, web beacons and other storage technologies. You can learn more about interest-based advertising from Facebook by visiting this page. To opt-out from Facebook’s interest-based ads follow these instructions from Facebook.

reCAPTCHA

Is a product from Google that helps protect websites from spam and abuse. A “CAPTCHA” is a test to tell human and bots apart. It is easy for humans to solve, but hard for “bots” and other malicious software to figure out. By adding reCAPTCHA to our site, we can block automated software while helping us welcome real users like you.

First, the reCAPTCHA algorithm will check to see if there’s a Google cookie placed on the computer being used. Then, an additional reCAPTCHA-specific cookie will be added to your browser, and a complete snapshot of the browser window at that moment in time will be captured, pixel by pixel. More information can be found at Google

reCAPTCHA and Google’s Privacy Policy. Alternatively, you can contact us by phone or email.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
  • analytics providers such as Google based outside the EU;
  • social media platforms such as Facebook based outside the EU
  • Contact, Financial and Transaction Data from providers of technical, payment anddelivery services.
  • Identity and Contact Data from partners such as Action Coach and Luv4Marketing4.

How we use your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • To contact you, following your enquiry, reply to any questions, suggestions, issues or complaints you have contacted us about;
  • Fulfilling our contract to provide you with the agreed service;
  • Make available our services to you;
  • Process your orders;
  • Take payment from you or give you a refund;
  • For statistical analysis and to get feedback from you about our services, website, and other activities. For example, occasionally we may invite you to review a service you’ve bought or used from us. If we do, it’s possible that we’ll use independent research and feedback providers to act on our behalf;
  • To power our security measures and services so you can safely access our website;
  • Help us understand more about you as a client, the products and services you consume, so we can serve you better;
  • Contact you about services from us;
  • Provide you with online advertising and promotions; and
  • Help answer your questions and solve any issues you have. How we keep you updated on our products and servicesWe will send you relevant offers and news about our products and services in a number of ways including by email, but only if you have previously consented to receive these marketing communications or we have a legitimate interest to do so and completed a legitimate interest assessment (LIA). When you register with us, we will ask if you would like to receive marketing communications, and you can change your marketing choices online, over the phone or in writing at any time. If you wish to amend your marketing preferences, you can do so by unsubscribing at the bottom of the email or by contacting us on the details outlined below.We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Legal Basis for Processing Your Information

The legal basis for processing your data is based on your specific consent/performance of a contract/compliance with a legal obligation/our legitimate interest that we will have requested at the point the information was initially provided, therefore we will not store, process or transfer your data outside the parties detailed above unless we have an appropriate lawful reason to do so.

5. Sharing: Who we might share your information with

We may share your personal data with other organisations in the following circumstances:

  • If the law or a public authority says we must share the personal data;
  • If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes ofpreventing fraud and reducing credit risk); or
  • From time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. However, all the information we share will be collected and anonymised, so neither you nor any of your devices can be identified from it.
  • External Third Parties to assist with delivery of our service, for example Action Coach, Luv4Marketing, Juiced Marketing. A full list of processors is available upon request.
    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Your rights over your information

Right to Access Your Personal Information

You have the right to access the personal information that we hold about you in many circumstances, by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 30 days from when your identity has been confirmed.

We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.

If you would like to exercise this right, please contact us as set out below.

Right to Correction Your Personal Information

If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

If you would like to exercise this right, please contact us as set out below.

Right to Object, Erasure or Limit Our Processing of Your Data

You have the right to object to us processing your personal information if we are not entitled to use it any more, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.

If you would like to exercise this right, please contact us as set out below.

For more information about your privacy rights

The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here https://ico.org.uk/for-the- public.

8. Retention: How long we keep your information for

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Unless otherwise required by law, your data will be stored for a period of 2 years after our last contact with you/some other identifiable action or period, at which point it will be deleted. Details of retention periods for different aspects of your personal data are available upon request by contacting us as outlined below.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Third party links and sharing your thoughts

You may be able to share information through social networks like LinkedIn and Facebook. For example, when you ‘like’, ‘share’ or review our Services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts so you are comfortable with how your information is used and shared on them.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for

their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

10. Security

Data security is of great importance to us and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your collected data.

We take security measures to protect your information including:

  • Limiting access to our offices to those that we believe are entitled to be there (by use of passes, key card access and other related technologies);
  • Implementing access controls to our information technology to only those who are authorised to access the information
  • We use appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard your information across all our computer systems, website and offices.

11. How to contact us

If you would like to exercise one of your rights as set out above, or you have a question or a complaint about this notice, the way your personal information is processed, please contact us by one of the following means:

By email: philipbudd@actioncoach.com
By post: Freedom House, 5 Abbeyfields, IP33 1AQ Thank you for taking the time to read our Privacy Notice.

This Notice was last updated on 06/05/2019