INSIGHT ALCHEMY LTD’S 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 data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the provisions of the UK General Data Protection Regulations that protect your personal data and we are responsible as ‘controller’ of that personal data 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 LTD, 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 data Any information relating to an identified or identifiable individual

Sensitive Data

[Special Categories of personal data]

Personal data revealing racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information concerning your health and genetic and biometric data. 

We do not collect any information about criminal convictions and offences.

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 www.JasminaAmbrus.com, including any data you may provide through this website when you sign up to our free resources 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 or products.

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

By providing us with your data, you warrant to us that you are over 13 years of age.

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 LTD 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 us 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 LTD

Email address: privacy [at] jasminaambrus [dot] com

Postal address:

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

Details of our Representative:

We have appointed EU Business Partners as our representatives in the EU for the purposes of Article 27 of the General Data Protection Regulation. You may contact our EU representative, as well as us directly, with any query that you may have in relation to your personal data. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

The contact details of our EU representative are as follows:

EU Business Partners
10 Ashe Street
Clonakilty
Co. Cork
P85 E403
Ireland

Point of contact: Flor McCarthy

Email address: info [at] eubusinesspartners [dot] com

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 March 27th 2021.
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 means any information about an individual from which that person can be identified. It does not include data where the identity has been removed [anonymised data].

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

  • Your name
  • Your company name, trading status, VAT number or local tax registration number, trading address, trading email address, trading telephone number
  • Your personal address
  • Your date of birth
  • Your financial details, e.g. payment card information, billing address and transaction information
  • Your image in the form of a photograph
  • Your image in the form of a video
  • Your personal or professional preferences
  • Your contact and purchase history
  • Any personal data you choose to share during your mentoring sessions [ audio ] recording
  • Your marketing preferences [in receiving marketing from us] and communication preferences
  • Your professional online presence accounts e.g. Facebook, Instagram, You Tube, Linkedin
  • Any other information you provide directly to us through our contact form, by email, by completing our application form, from accounts you link to us or otherwise such as completing our test, survey, responding to promotion by entering a free giveaway or competition
  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website.
  • Information to enable us to undertake credit or other financial checks on 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.

Sensitive Data

Sensitive data [otherwise known as Special Categories of Personal Data’] refers to personal data revealing racial or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information concerning your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

We may need to collect the following sensitive data about you: religious or philosophical [spiritual] beliefs, sexual orientation, sex life and information about your wellbeing, relevant to the performance of your business, 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 services or products]. In this case, we may have to cancel a service or product you have with us but we will notify you if this is the case at the time.

We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.

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;
• 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.
• request our marketing and communication to be sent to you;
• supply us with your image in the form of a photograph or a video;
• complete our test, survey or enter a free giveaway, competition or promotion; or
• give us testimonial or contact us; or
• engage with us on social media; or

• 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 UK and/or the EU; and
(b) marketing automation platforms such as Aweber or Infusionsoft based outside the UK and/or the EU.
(c) advertising networks such as Facebook based outside the UK and/or the EU

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

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

• Data relating to your identity and contact information from social media websites such as Facebook or LinkedIn, based outside the UK and/or 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 for what purpose and on what lawful grounds we process your personal data for.

For what purpose we use your personal data for On what lawful grounds we process your personal data

CLIENT data or personal data we have acquired in relation to:

  • registering you as a new client
  • providing services or products to you
  • processing and delivering your order including:

a. managing payment, fees and charges
b. collecting and recovering money owed to us

  • keeping records of the contract processing
  • updating and enhancing client records
  • notifying you about changes to our terms or privacy policy
  • informing you about updates to the service or product
  • asking you to leave a testimonial or take our test or survey

Processing is necessary for:

  • the performance of our contract with you or
  • taking steps at your request before entering into a contract with us
  • the compliance with our legal and regulatory obligations

and for our legitimate interest in:

  • record keeping
  • informing you about the updates to the services or products
  • establishing, pursuing or defending legal claim as responsible business operations [including recovering debts due to us]
  • studying how our clients use our services and products
  • informing our marketing strategy

PROSPECT data or personal data we have acquired when you:

  • asked about our services or products [whether thru our website or otherwise] that we process:

a. in order to reply to your enquiry and
b. keep relevant records

  • signed up for any of our free resources [whether thru our website or otherwise] that we process:

a. in order to send you those free resources and
b. reply to your communication about those resources and
c. keep relevant records

Processing is necessary for:

  • taking steps at your request before entering into a contract with us
  • supplying you with free resources at your request and always with your consent

and for our legitimate interest in:

  • record keeping
  • replying to your communication
  • establishing, pursuing or defending legal claim

MARKETING data or personal data we have acquired when you:

  • shared with us of your marketing preferences
  • granted us consent to send you details about our services and products

 

Processing is necessary for:

  • allowing us to send you marketing communications
  • allowing you to take part in promotions such as competitions, prize draws and free giveaways
  • delivering relevant website content and advertisement to you and
  • measure and understand the effectiveness of the advertisement we serve to you

and for our legitimate interest in:

  • studying how clients use our services and products
  • developing them
  • informing our marketing strategy
  • growing our business

USER data or personal data we have acquired:

  • through cookies on our website or other online services
  • when you posted for publication on our website or other online services

Processing is necessary for:

  • operating our website
  • ensuring relevant content is provided to you
  • ensuring the security of our website
  • maintaining backups of our website and databases
  • enabling publication and administration of our website, other online services and business

and for our legitimate interest in:

  • enabling us to properly administer our website and our business

TECHNICAL data or personal data we acquired:

  • through your use of our website and online services such as: your IP address, your login data, details about your browser, length of visit to pages on your website, page views and navigation path, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website and other online services.

Processing is necessary for:

  • analysing your use of our website and other online services
  • administering and protecting our business and website
  • delivering relevant website content and advertisement to you and
  • understanding the effectiveness of our advertising

and for our legitimate interest in:

  • properly administering our website and business
  • informing our marketing strategy
  • growing our business
 

Ensuring the confidentiality of commercially sensitive information

Processing is necessary for:

  • the compliance with our legal and regulatory obligations

and for our legitimate interest in:

  • protecting trade secrets and other commercially valuable information

Statutory returns

Processing is necessary for:

  • the compliance with our legal and regulatory obligations

Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies

External audits and quality checks including accreditations and the audit of our accounts

Processing is necessary for:

  • the compliance with our legal and regulatory obligations

and for our legitimate interest in:

  • maintaining our accreditations so that we can demonstrate we operate at the highest standards

Ensuring safe working practices, staff administration and assessments.

Ensuring business policies are adhered including policies covering security and internet use

Processing is necessary for:

  • the compliance with our legal and regulatory obligations

and for our legitimate interest in:

  • making sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Statistical analysis to help us manage our business in relation to our financial performance, client base, product range or other efficiency measures

Operational reasons, such as improving efficiency, training and quality control

Processing is necessary for our legitimate interest in:

  • being as efficient as we can so we can deliver the best service for you at the best fee

Preventing unauthorised access and modifications to systems

Administering and protect our business and our website including: troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

Processing is necessary for:

  • the compliance with our legal and regulatory obligations

and for our legitimate interest in:

  • preventing and detecting criminal activity that could be damaging for us and for you
  • 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

The above table does not apply to sensitive data, 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. MARKETING COMMUNICATIONS

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

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests [namely to grow our business]. See above ‘For what purpose and on what grounds we process your personal data for’.

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

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

• contacting us at support [at] jasminaambrus [dot] com or privacy [at] jasminaambrus [dot] com
by following the opt-out links on any marketing message sent to you

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, etc.

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 grounds for processing 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 DATA WITH

We may have to share your personal data with the parties set out below:

• Service providers who provide IT and system administration services.
• Service providers who provide teaching materials fulfilment services
• Service providers who provide VIP client experience services
• Professional advisers including accountants, lawyers, bankers, auditors and insurers
• Government bodies that require us to report processing activities.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

7. INTERNATIONAL TRANSFERS

We are subject to the provisions of the UK General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

• We may transfer your personal data to countries that the relevant regulatory authorities in the United Kingdom have approved as providing an adequate level of protection for personal data by; or
• If we use US-based providers that are part of a UK regulator approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place;
• Where we use certain service providers who are established outside of the UK, we may use specific contracts or codes of conduct or certification mechanisms approved by the United Kingdom regulators which give personal data the same protection it has in the UK.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

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

• Service providers acting as processors based outside the UK and/or the EU who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based outside the UK and/or the EU 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 DATA WILL BE KEPT

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements:

• 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.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements. Different retention periods apply for different types of personal data.

For tax purposes the law requires us to keep basic information about our clients [including Contact, Identity, Financial and Transaction Data] for six years after they stop being clients.

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