We want you to know that you can use this site with complete confidence; we take your privacy very seriously.
We hope the following sections will answer any questions you have but if not, please do get in touch with us via email at firstname.lastname@example.org
We are committed to putting the consumer first and being transparent on how we collect, use and protect your personal information. For the purposes of the General Data Protection Regulation (GDPR) the data controller is Irate Investment Ltd. (referred to in this policy as “we”, “us” or “our”). We want you to be confident that the personal information you give us is safe and secure and understand how we use it to offer you a better and more personalised experience on our Site.
- Who we are as a company;
- The legal basis for collecting personal information;
- The personal information we collect;
- How and why we collect and use your personal information;
- Where your personal information is stored and/or processed;
- How long we will hold your information for;
- Who we share your personal information with and why;
- The use of children’s personal information;
- The rights and choices you have when it comes to your personal information;
- The steps we take to ensure your information is kept secure and confidential;
- How you can contact us or the regulator for further information.
2. Who we are
Here are the details that we as ‘data controller’ are required to give to you in accordance with Data Protection Legislation (please note this means the Data Protection Act up to and including 24th May 2018 and from 25 May 2018 and onwards the General Data Protection Regulation (GDPR) and any other applicable law which relates to the protection of individuals rights with regard to the processing of personal data):
Our Site address is www.paulclaireaux.com
Our company name is Irate Investment Ltd, registered in England and Wales, Company No. 8791354.
Our registered address is at: 75-77 Buccleauch Street, Barrow in Furness, Cumbria LA14 1QQ.
Our nominated representative is Paul Claireaux.
3. The legal basis for collecting your information
The law on data protection sets out a number of different reasons for which a company may collect and process your personal information, including:
- In specific situations, we can collect and process your data with your consent.
- For example, when you sign up for our newsletter or promotions by providing your email address.
- When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
- Contractual obligations
- In certain circumstances, we need your personal data to comply with our contractual obligations.
- For example, if you are a member of our online community you must provide your name, email address and postal address so that we can deliver invoices.
- Legal compliance
- If the law requires us to, we may need to collect and process your data.
- For example, we can pass on details of people involved in fraud or other criminal activity affecting our Site to law enforcement.
- Legitimate interest
- In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
- For example, we may use your address details to send you invitations to workshops and other events that we think might interest you.
4. What sort of personal information do we collect?
When you sign up to our member’s area, you may provide us with:
- Your personal details, including without limitation your name, postal and billing addresses, email addresses, phone numbers, date of birth and title.
- For your security, we’ll also keep an encrypted record of your login password.
When you participate on Site pages through comments, you may provide us with:
- Your email address, IP address and social media username.
When you register for certain products (such as our newsletter) via forms on our Site, you may provide us with:
- Your personal details, including your email address, name and postal address.
When you register for (and attend) our events, you may provide us with:
- Your personal details, including without limitation your name, postal and billing addresses, email addresses, phone numbers, date of birth, title, dietary requirements and accessibility requirements.
- Images of yourself in photographs at the event (with your permission).
When you visit our Site we may collect information about your online browsing behaviour and any devices you have used to access our Site (including your IP address, browser type and mobile device identifiers).
Please note that we do not store debit/credit card details.
5. How do we collect this personal information?
It will always be clear what personal information we are collecting and why. We may collect this information under any of the following circumstances:
- When you book to attend an event.
- When you sign up for our newsletter and promotions via forms on our Site.
- When you join our online member’s area.
- When you book a meeting with us.
- When you’ve given a third-party permission to share with us the information they hold about you.
- When you deliver a service or a product to us as a supplier.
We collect and may use your personal information to:
- Contact you in response to the communications that you have directed at us. We want to be able to help you so we use personal information to provide clarification or assistance in response to your communications;
- Invite you to take part in polls and other market research activities carried out by us and by other organisations on our behalf. Any feedback you provide will only be used to improve our Site and will not be published. However, if we contact you about this, you do not have to take part in the activities;
We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law (see section 9 below).
6. How and why do we use your personal information?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the information we have about you.
We then use this to keep you informed about services that are most likely to interest you as well to provide business insights, ideas and connections. We may also send you instructions on how to join our member’s area.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
We may also use your personal information in order to:
- Send you invitations to relevant events and workshops.
- Send you newsletters with insights and promotions.
- Check arrangements for meetings or events (by mobile phone, text or email).
- Ensure any catering arrangements at events meet your dietary requirements.
- Ensure that any accessibility requirements can be handled at any event.
- To send you summary information and write ups from workshops.
- To process any event booking.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to our marketing communications or sending third party direct marketing communications to you via email or text message. Of course, if you wish to change how we use your information, you’ll find details in the “Your rights” section below. However, you acknowledge this will limit our ability to provide the best possible services to you.
Some third-party technology we use (e.g. embedded videos, social sharing) also drop cookies to improve your experience on their sites.
8. Where do we store and process your personal information?
We may transfer your collected data to third parties for storage outside the European Economic Area (EEA). For example, your personal information may be processed outside the EEA to fulfil your order or administer payment.
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 the Europe and the US. For further details, see the European Commission: EU-US Privacy Shield.
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 data collected through our Site.
9. How long do we hold your personal information for?
10. Who do we share your personal information with and why?
We will share your personal information with trusted third parties who act as data processors. We check that they are GDPR compliant and have processing agreements in place with each of them.
We provide only the information they need to perform their specific services and they may only use your information for the exact purposes we specify in our contract with them. If we stop using their services, any of your information held by them will either be deleted or rendered anonymous.
These include but are not limited to:
We do not sell your information to any third party nor do we share your data with any third party for their own direct marketing purposes.
We may also disclose your information in the following cases:
- If we want to sell our business, or our company, we can disclose it to the potential buyer;
- If we want to sell or buy any business, or assets, we can disclose your personal information to the potential buyer or seller of such business or assets;
- We can disclose it to other businesses in our group, which means our subsidiaries, our ultimate holding company and its subsidiary as defined in Section 1159 of the UK Companies Act 2006;
- We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights;
- In connection with legal proceedings (including prospective proceedings);
- In order to establish or defend our legal rights; and
- We can exchange information with others to protect against fraud or credit risks.
11. Personal information of children
We do not knowingly collect or store any personal information about children under the age of 16. If you are aged under 16 please get your parent or guardian’s permission before you provide any personal information to us.
12. Your rights
You already have certain rights under existing data protection legislation, including a right to request a copy of the personal information we hold on you, if you request it in writing. From 25 May 2018 you now also have the following rights:
- Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete;
- Right to erase: the right to request that we delete or remove your personal information from our systems;
- Right to restrict our use of your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it;
- Right to data portability: the right to request that we move, copy or transfer your personal information;
- Right to object: the right to object to our use of your personal information including where we use it for our legitimate interests, or where we use your personal information to carry out profiling to inform our market research and user demographics. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we’re continuing to process your personal information.
To exercise any of these rights please contact email@example.com
We will use reasonable efforts consistent with our legal duty to provide you with your rights in accordance with data protection legislation.
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any data subject access request you make. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
We are committed to ensuring your personal information is protected and held securely. However, the internet is not a secure medium and we cannot accept responsibility for the security of an email during transmission or non-delivery of that email. By using our Site you accept the inherent risks of providing information online and will not hold us responsible for any breach of security.
14. Making a complaint
If you believe we have not processed any of your personal information in accordance with Data Protection Legislation or you have been affected by non-compliance you can make a complaint to us at firstname.lastname@example.org
If you feel that your information has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal information, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (please note we can’t be responsible for the content of external websites).
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.
Effective as of: 03/07/2018