We are committed to respecting and protecting your personal data.
This Policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and what choices you have. It relates to all our business activities, not just this website.
We may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our services, you’re agreeing to be bound by this Policy.
Any questions regarding this Policy and our privacy practices should be sent by email to: email@example.com
Updated: 24th May 2018
1. Who are we?
Anna Lupton Business Consultant is a trading name of Anna Lupton. The term ‘Anna Lupton’ or ‘us’ or ‘we’ refers to the owner of the website. The term ‘you’ refers to the user or viewer of our website. We provide PR and marketing services for clients in the UK. The business address for Anna Lupton Business Consultant is Carr House Farm, Ampleforth, North Yorkshire, Y062 4ED. Full contact details can be found here: http://www.annalupton.co.uk/contact/.
2. How do we collect information from you?
We obtain information about you when you contact us to enquire about our services.
3. What information do we collect & how is it used?
We collect information to allow us to fulfil our business obligations to our customers, and to respond to business enquiries. The table in section 3.3 below outlines exactly what information we collect, and for what purpose.
3.0. Sensitive Data
We do not gather sensitive personal data (e.g. health, genetic, biometric data; racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation, and criminal convictions). We expressly request that you do not provide any such sensitive data to us.
3.1. Children’s information
Our services are not directed to children under 13. If you learn that a child under 13 has provided us with personal information without consent, please contact us.
3.2. Third Parties
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
We may pass your information to third party service providers who we have engaged for the purpose of completing tasks and providing services to you on our behalf. We disclose only the personal information that is necessary to deliver the service.
We also use a number of 3rd party services to help us fulfil our contractual obligations. These 3rd party services are listed in full below; we have verified that these 3rd party services are GDPR compliant (or are working towards GDPR compliance), and are certified under the EU-US Privacy Shield Framework (or are working towards certification) where these organisations are based outside of the EU.
The following table outlines the personal data we collect and for what purpose. The table also outlines the 3rd parties the data is processed by or shared with, and how long the data is stored for:
|Name||What||Legal Ground||Purpose||3rd Parties||Data Retention|
|Customer & supplier contact information, details of enquiries||Contract||To allow initial and ongoing contact with prospective customers, customers, suppliers, etc.||Paragon Internet Group Ltd||Until request for deletion|
|Invoicing||Customer & supplier purchase history & contact/billing info.||Legal obligation||For invoicing||Indefinitely, for on-going invoicing and accounting records|
|Analytics||Website visitor behaviour (anonymised – full IP address is NOT stored)||Legitimate interests||To analyse popular content, website performance, etc – so we can further improve||Google Analytics – We have signed DPA & anonymised IP addresses||26 months|
|Server Logs||IP address||Legal obligation||To help prevent DoS (Denial of Service) attacks; for website security and diagnostics||Paragon Internet Group Ltd||Indefinitely|
|DNS Log Data||IP address, system configuration information, etc||Legitimate interests||Cloudflare provides DNS, web optimization and security services for our website||Cloudflare||Indefinitely|
|Email Marketing||Contact details (only for people who specifically opt-in to our email newsletter)||Legitimate interests||To update customers about news & offers that might be of interest to them||Mailchimp||Indefinitely (recipients can unsubscribe to our marketing emails at any time)|
4. Controlling your information
You have certain rights concerning the information we hold about you, as defined under the General Data Protection Regulation.
4.0. Requesting a copy of your information
You may request a copy of any data we hold about you. Upon request, we will provide all the personal data we hold on record about you. You may email a request to firstname.lastname@example.org or send a request in writing to:
Carr House Farm
4.1. Updating or correcting your information
The accuracy of your information is important to us. If you change email address, or any of the other information we hold is inaccurate or out of date, please contact us so we may correct our records.
4.2. Deleting your information
You have the right to request erasure of your personal information. Unless there is a compelling reason for the data not to be erased (for example, if we need to use that data to fulfil our contractual or legal obligations), your personal data will be deleted on request.
4.3. Automated decision making
We do not use any personal information for automated decision making or profiling; your data is not subject to automated decision making or profiling.
5. Use of ‘cookies’
Google Analytics sets cookies to help us accurately estimate the number of visitors to the website and what content is most popular. This helps to ensure that our website is responding to your needs in the best way possible.
We use Cloudflare to provide web optimization and security services for our website. A cookie is set by the CloudFlare service to identify trusted web traffic. It does not store any personally identifiable information.
By using and browsing the Anna Lupton Business Consultant website, you consent to cookies being used in accordance with this Policy.
If you do not consent, you must turn off cookies or refrain from using the site. Most browsers allow you to turn off cookies. To do this, look at the ‘help’ menu on your browser. Switching off cookies should not noticeably restrict your use of this website.
Anna Lupton Business Consultant takes security seriously. In order to protect your information from loss, misuse or unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. These steps include the following:
- Data minimisation
- Password best practice
- Security best practice concerning devices (PCs, laptops, mobile devices), online accounts, website hosting, physical access and storage
- Staff training and accountability on data protection
7. Data Breaches
Should a data breach occur where appropriate, Anna Lupton Business Consultant will promptly notify you of any unauthorized access to your personal information.
If you wish to raise a complaint on how we have handled your personal information, you can contact us directly and we will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).