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. |
Click on the links below to go straight to more information on each area:
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW AND WHY WE USE YOUR PERSONAL DATA
6. WHO WE SHARE YOUR PERSONAL DATA WITH
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.
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 May 25th 2023.
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 Matomo Analytics based inside 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:
a. managing payment, fees and charges
|
Processing is necessary for:
and for our legitimate interest in:
|
|
PROSPECT data or personal data we have acquired when you:
a. in order to reply to your enquiry and
a. in order to send you those free resources and |
Processing is necessary for:
and for our legitimate interest in:
|
|
MARKETING data or personal data we have acquired when you:
|
Processing is necessary for:
and for our legitimate interest in:
|
|
USER data or personal data we have acquired:
|
Processing is necessary for:
and for our legitimate interest in:
|
|
TECHNICAL data or personal data we acquired:
|
Processing is necessary for:
and for our legitimate interest in:
|
|
Ensuring the confidentiality of commercially sensitive information |
Processing is necessary for:
and for our legitimate interest in:
|
|
Statutory returns |
Processing is necessary for:
|
|
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:
and for our legitimate interest in:
|
|
Ensuring safe working practices, staff administration and assessments. Ensuring business policies are adhered including policies covering security and internet use |
Processing is necessary for:
and for our legitimate interest in:
|
|
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:
|
|
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:
and for our legitimate interest in:
|
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.
10. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data including:
| Access |
The right to be provided with a copy of your personal data [the right of access] |
| Rectification |
The right to require us to correct any mistakes in your personal data. |
| To be forgotten |
The right to require us to delete your personal data – in certain situations. |
| Restriction of processing |
The right to require us to restrict processing of your personal data – in certain circumstances |
| Data portability |
The right to receive the personal data 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:
|
If you are within the UK, you can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You will not have to pay a fee to access your personal data [or to exercise any of the other rights]. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
If you would like to exercise any of those rights, please:
• email or write to us [see above: ‘How to contact us’] and
• we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data [or to exercise any of your other rights]. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response; and
• let us know what right you want to exercise and the information to which your request relates.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are within the UK and are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office [ICO], the UK supervisory authority for data protection issues [www.ico.org.uk].
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.
If you are within the EU and are not happy with any aspect of how we collect and use your data, you have the right to complain to the data protection authority of the country in which you are based. 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