INSIGHT ALCHEMY’s LTD WEBSITE PRIVACY POLICY

INTRODUCTION

Welcome to Insight Alchemy’s privacy policy.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union [including in the United Kingdom] and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our Insight Alchemy Limited, which is a company registered in England and Wales with registration no 8642075 and whose registered office is at 71-75 Shelton Street Covent Garden London WC2H 9JQ.
Personal information Any information relating to an identified or identifiable individual
Special Category

personal information

Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership

Genetic and biometric data

Data concerning health, sex life or sexual orientation

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you [both positive and negative]) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you [unless we have your consent or are otherwise required or permitted to by law]. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Insight Alchemy collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or submit an application form showing interest in purchasing our service. It also gives information on how Insight Alchemy collects and processes your personal data once you have entered into a contract for our services.

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

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Insight Alchemy Limited is the controller and responsible for your personal data [referred to as “Insight Alchemy”, “we”, “us” or “our” in this privacy policy].

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact Jasmina Ambrus, using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: Insight Alchemy Limited

Email address: privacy[@]insightalchemy.com

Postal address:

INSIGHT ALCHEMY LTD
71-75 Shelton Street; Covent Garden
London WC2H 9JQ
England

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.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on October 23rd 2018.

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.

THIRD-PARTY LINKS

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 policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

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).

We may collect, use, store and transfer the following personal information about you:

• your name and contact information, including email address and telephone number and company details
• Information to enable us to check and verify your identity, e.g. your date of birth
• your gender information
• your image in the form of a photograph
• location data
• your billing information, transaction and payment card information
• your personal or professional interests
• your professional online presence, e.g. your LinkedIn profile
• your contact history, purchase history and saved items
• information from accounts you link to us, e.g. Facebook
• information to enable us to undertake credit or other financial checks on you
• Information about how you use our website, IT, communication and other systems
• your responses to surveys, competitions and promotions

This personal information is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

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 data relating to how you use our website 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 policy.

We may collect Sensitive Personal Information (otherwise known as ‘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) where you offer this information during the course of our mentoring sessions and during the performance of our services. We will only collect such data where this is necessary for the performance of our contract and we have your specific consent to do so.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you [for example, to provide you with goods or services]. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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 Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• subscribe to our service or publications;
• create an account on our website;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us; or
• engage with us on social media; or
• Enter into a contract with us to supply services and engage with us in the performance of those services throughout the duration of that contract.

• 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. Please see our cookie policy for further details.

• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU; and

(b) marketing and automation platforms such as Aweber based outside the EU.

• Data relating to your contact details, financial information and transactions with us from providers of technical, payment and delivery services such as PayPal based outside the EU

• Data relating to your identity and contact information from publicly available sources such as Companies House and the Electoral Register based inside the EU.

• Data relating to your identity and Contact information from social media websites such as LinkedIn or Facebook, based outside the EU

4. HOW AND WHY WE USE YOUR PERSONAL DATA

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:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests [or those of a third party] and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation
• Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

 

What we use your personal information for Our reasons
To register you as a new customer

To provide services to you.

For the performance of our contract with you or to take steps at your request before entering into a contract
To process and deliver your order, including:

a)     manage payments, fees and charges

b)     collect and recover money owed to us

For the performance of a contract with you.

Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To prevent and detect fraud against you or our clients For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies To comply with our legal and regulatory obligations
 

Ensuring business policies are adhered to, e.g. policies covering security and internet use

For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures, so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
Preventing unauthorised access and modifications to systems For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Updating and enhancing customer records For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services to:

—existing and former customers;

—third parties who have previously expressed an interest in our services;

—third parties with whom we have had no previous dealings.

For our legitimate interests, i.e. to promote our business to existing and former customers

 

 

 

 

To administer and protect our business and our website [including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data] For our legitimate interests [for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise].

To comply with a legal obligation.

 

External audits and quality checks, e.g. for accreditations and the audit of our accounts For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

 

The above table does not apply to special category personal information, which we will only process with your explicit consent.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

5. PROMOTIONAL COMMUNICATIONS

We may use your personal information to send you updates [by email, text message, telephone or post] about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes [see above ‘How and why we use your personal information’]. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• contacting us at support@jasminaambrus.com or privacy@insightalchemy.com
• using the ‘unsubscribe’ link in emails

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

COOKIES

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. For more information about the cookies we use, please see our cookie policy.

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.

6. WHO WE SHARE YOUR PERSONAL INFORMATION WITH

We routinely share personal information with:

• third parties we use to help deliver our services to you, e.g. payment service providers, warehouses and delivery companies;
• other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
• third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
• our bank/s;
• third parties who provide us with advice and assistance in running our business, e.g. legal advisors, accountants and auditors.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7. INTERNATIONAL TRANSFERS

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area [EEA], e.g.:

• with your and our service providers located outside the EEA;
• if you are based outside the EEA;
• where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

Countries in the EEA which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information.

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.

The third parties we may transfer your data to are as follows:

• Service providers acting as processors based in the US who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EU and US who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

8. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT

We will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

10. YOUR LEGAL RIGHTS

You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal information [the right of access]
Rectification The right to require us to correct any mistakes in your personal information
To be forgotten The right to require us to delete your personal information—in certain situations
Restriction of processing The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:

—at any time to your personal information being processed for direct marketing [including profiling];

—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision-making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to us -see above: ‘How to contact us’; and
• let us have enough information to identify you [e.g. your full name, address and customer or matter reference number];
• let us have proof of your identity and address [a copy of your driving licence or passport and a recent utility or credit card bill]; and
• let us know what right you want to exercise and the information to which your request relates