DEFINITIONS AND INTERPRETATION
|“Data Protection Laws”
|All applicable data protection and privacy legislation in force from time to time in the UK including without limitation the UK GDPR, the Data Protection Act 2018 and all other legislation and regulatory requirements in force from time to time which apply to the use of Personal Data.
|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).
|“It’s SO Simple”
|It’s SO Simple Limited, a company incorporated with the registered number 12882612 whose registered office is at 64 New Cavendish Street, London, England, W1G 8TB.
|The retained EU law version of the General Data Protection Regulation ((EU) 2016/679).
|“User” and “You”
|Any third party that is a client of ours or accesses the Website and is not either (i) employed by It’s SO Simple and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to It’s SO Simple and accessing the Website in connection with the provision of such services; and
|The website that You are currently using, https://www.itssosimple.co.uk/ and any sub-domains of this site unless expressly excluded by their own terms and conditions.
- The singular includes the plural and vice versa;
- A reference to a person includes firms, companies, government entities, trusts and partnerships;
- “including” is understood to mean “including without limitation”;
- Reference to any statutory provision includes any modification or amendment of it;
- For purposes of the applicable Data Protection Laws, It’s SO Simple is the “data controller”. This means that It’s SO Simple determines the purposes for which, and the manner in which your Personal Data is processed.
PERSONAL DATA COLLECTED
- We may collect the following Personal Data from You:
- Identity data such as name, title, date of birth and gender;
- Contact data such as email address, billing address and telephone numbers;
- Financial data such as bank account and payment card details;
- Transaction data such as payments from you;
- Technical data such as internet protocol address, any login data, browser type and version from the technology you use to access this Website;
- Usage data such as information about how you use the Website; and
- Medical and health related data,
HOW WE COLLECT PERSONAL DATA
- We collect Personal Data in the following ways:
- Personal Data is given to us by You (please refer to paragraph 7 below); and
- Personal Data is collected automatically (please refer to paragraph 8 below).
PERSONAL DATA THAT IS GIVEN TO US BY YOU
- It’s SO Simple will collect your Personal Data in a number of ways, for example:
- When You contact us through the Website, by telephone, post, email or through any other means;
- When You make payments to us, through this Website or otherwise;
- When You use our services,
PERSONAL DATA THAT IS COLLECTED AUTOMATICALLY
- To the extent that You access the Website, we will collect your Personal Data automatically, for example:
- We automatically collect some information about your visit to the Website. This information helps us to make improvements to the website content and navigation, and includes your IP address, the date, times and frequency with which You access the Website and the way You use and interact with its content.
- Where cookies are used, a small amount of information is downloaded to your computer or device when You visit the Website. Cookies will make your browsing experience better by allowing the Website to remember your actions and preferences. Cookies will also provide information on how people use the Website, for instance, whether it’s their first time visiting of if they are a frequent visitor. We do not share the information collected by the cookies with any third parties. Where cookies are used, You can choose which cookies we can set by selecting the appropriate options on our Website.
OUR USE OF PERSONAL DATA
- We will only use your Personal Data when the law allows us to do so. Most commonly, we will use your Personal Data in the following circumstances:
- Where we need to perform the contract we have entered into with You;
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal obligation; or
- For our internal record keeping purposes.
- You have the right in certain circumstances to object to your Personal Data being used by us. Please refer to the heading titled “Your rights” for more information.
- We may arrange that card or payment data You submit for payment of your programme is stored for the purpose of processing your subscription charge. All financial data is stored by our third-party payment processors, and we do not have access to these details.
WHO WE SHARE PERSONAL DATA WITH
- We may share your Personal Data with the following groups of people for the following reasons:
- Our employees and/or professional advisors – to provide You with the It’s SO Simple programme; and
- Our third-party payment processors – for processing the payments made by You for the provision of the It’s SO Simple programme.
- We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We only permit the above third parties to process your Personal Data for specified purposes and in accordance with our instructions.
KEEPING PERSONAL DATA SECURE
- 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 and third parties who have a need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
- We will use technical and organisational measures to safeguard your Personal Data, for example:
- Access to your account is controlled by a password and a user name that is unique to You.
- We store your Personal Data on secure and password protected computers.
- Our computer systems are further protected with anti-virus and firewall software.
- Technical and organisational measures include measures to deal with any suspected data breach. If You suspect any misuse or loss or unauthorised access to your Personal Data, please let us know immediately by contacting us via this email address: firstname.lastname@example.org.
PERSONAL DATA RETENTION
- We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
- To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
- You have the right to:
- Request access to your Personal Data (commonly known as a “data subject access request”). This enables You to receive a copy of the Personal Data we hold about You and to check that we are lawfully processing it. If we provide You with access to the information we hold about You, we will not charge You for this, unless your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell You the reason why.
- Request correction of the Personal Data that we hold about You. This enables You to have any incomplete or inaccurate data we hold about You corrected, though we may need to verify the accuracy of the new data You provide to us.
- Request erasure of your Personal Data. This enables You to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where You have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of your request.
- Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes You want to object to processing on this ground as You feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your Personal Data. This enables You to ask us to suspend the processing of your Personal Data.
- Request the transfer of your Personal Data to You or to a third party. We will provide to You, or a third party You have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which You initially provided consent for us to use or where we used the information to perform a contract with You.
- To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Personal Data (where consent is our legal basis for processing your Personal Data), please contact us via email on email@example.com.
- 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 the period for which we hold it.
LINKS TO OTHER WEBSITES
CHANGE OF BUSINESS OWNERSHIP AND CONTROL
- We may also disclose Personal Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps with the aim of ensuring your privacy is protected.
- It is important that the Personal Data we hold about You is accurate and current. Please keep up informed if your Personal Data changes during your relationship with us.
You may contact It’s SO Simple by email at firstname.lastname@example.org.