Plenitude Consulting understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.plenitudeconsulting.com (“our site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of our site;
means a small text file placed on your computer or device by our site when you visit certain parts of our site and/or when you use certain features of our site. Details of the Cookies used by our site are set out in section 13, below;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to us via our site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
means Plenitude Consulting, a limited company registered in England under company number 07593870, whose registered address is 30th Floor, Bank Street, Canary Wharf, London, E14 5NR.
2. Information About Us
Our site is owned and operated by a limited company registered in England under company number 07593870, whose registered address is 30th Floor, Bank Street, Canary Wharf, London, E14 5NR.
We are not required to appoint a Data Protection Officer. However, the responsibilities of such an officer have been assumed by our Managing Director. These responsibilities include:
- Handling reported data breaches and informing the Information Commissioner’s Office (ICO) where necessary;
- Defining appropriate policies and procedures; and
- Responding to data subject request to access the data we hold on them and correcting it where necessary.
3. What Does This Policy Cover?
4. Your Rights
- As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:
- The right to be informed about our collection and use of personal data;
- The right of access to the personal data we hold about you (see section 12);
- The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
- The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 14);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
For further information about your rights, please contact the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113. Alternatively, please contact your local Citizens Advice Bureau.
5. What Data Do We Collect?
- business, company name;
- contact information such as email addresses and telephone numbers;
- demographic information such as post code, preferences, and interests;
- IP address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on Our site, and the site you exit to;
- property address;
- any documents you submit to us (such as CVs)
6. How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, We may use your data for the following purposes:
- Providing and managing your Account;
- Providing and managing your access to our site;
- Personalising and tailoring your experience on our site;
- Supplying our products and services to you (please note that we require your personal data in order to enter into a contract with you);
- Personalising and tailoring our products and services for you;
- Replying to emails from you;
- Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by contacting us directly);
- Market research;
- Analysing your use of our site and gathering feedback to enable us to continually improve our site and your user experience;
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email telephone, text message and post with information, news and offers on our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- Third parties (including names) whose content appears on our site may use third party Cookies, as detailed below in section 13. Please note that we do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
- You have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it. However, please be aware that this may impact the supply of our products and services to you and be subject to the terms of any contractual agreements you have signed up to.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. However, where legally required, we may retain your personal data for an extended period of time (a minimum of 6 years) after a contractual relationship has ceased.
7. How and Where Do We Store Your Data?
We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.
Data security is very important to us. We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have a procedure to deal with any suspected personal data breach and will notify you, and other regulators, where we are legally required to do so.
8. Do We Share Your Data?
We may compile statistics about the use of our site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as affiliates and partners. Data will only be shared and used within the bounds of the law.
In limited and necessary circumstances, your personal data may be transferred outside of the EEA or to an international organisation to comply with our legal or contractual requirements.
Where we do send your information to third parties who are based outside of the EEA we will only share your information with them because the following safeguards have been put in place:
- The country we send your information to is deemed to provide an adequate level of protection by the European Commission;
- The information is being transferred between organisations which are engaged in the same economic enterprise, or within our corporate group, and we have an agreement in place which sets out how your privacy will be protected; and
- The entities we transfer your information to are based in the US and are part of the Privacy Shield which requires them to provide a similar level of protection to European standards.
- In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
10. How Can You Control Your Data?
In addition to your rights under the GDPR, set out in section 4, when you submit personal data via our site, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by at the point of providing your details or by contacting us directly).
11. Your Right to Withhold Information
You may access certain areas of our site without providing any data at all. However, to use all features and functions available on our site you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is ordinarily payable and we will aim to provide any and all information in response to your request free of charge. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint.
Please contact us for more details at firstname.lastname@example.org, or using the contact details below in section 14.
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14. Contacting Us