Privacy and cookies policy

Last updated November 2022.

We respect your privacy and are committed to protecting your personal data. This policy explains the terms on which we collect and process your personal data, and how we protect it when you visit our website at https://www.dataledconsulting.com/, when you sign up to our newsletter on our website, when you interact with our website by commenting on our articles, or by engaging us to provide our consultancy services. In addition, this policy explains your privacy rights and how the law protects you.

1. Who we are

We are Data Led Consulting Ltd, a company registered in England and Wales under company number 14436257 with our registered office at 27 Old Gloucester Street, London, WC1N 3AX, United Kingdom (“we”, “us” or “our”). For data protection purposes, we are the controller responsible for your personal data.

We comply with our obligations under the Data Protection Act 2018 and the EU law retained version of the General Data Protection Regulation (EU) (2016/679) (together, the “data protection legislation”). If any of these laws are replaced or superseded, will also comply with those.

As part of our data protection obligations, we have registered with the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk), and our registration number is ZB468677. You have a right to make a complaint to the ICO at any time, but we would appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance by email to info@dataledconsulting.com.

2. The data we collect about you

Personal data/information means any information about an individual from which that person can be identified. It doesn’t include anonymous data. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey responses, and interactions with our website.
• Usage Data includes information about how you use our website, products, and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Aggregated Data such as statistical or demographic data for any purpose, isn’t considered personal data in law as this data will not directly or indirectly reveal your identity. We may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

We do not collect any 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). We also don’t collect any information about criminal convictions and offences.

3. How is your personal data collected?

We use different methods to collect personal data from and about you including through:

• Direct interactions. You may give us your Identity and Contact by signing up to the newsletter on our website, by interacting with us via our website, by filling in forms or by corresponding or engaging with us by post, phone, email, social media or otherwise.
• 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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, such as Google, Companies House, or the electoral register.

4. How we use your personal data?

We will only use your personal data when we can rely on a legitimate (lawful) basis, such as:

• 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.

5. Purposes for which we will use your personal data

We have set out below the ways we may use your personal data, and which of the legitimate bases we rely on to do so:

Marketing

You will receive marketing communications from us if you have requested information from us and you haven’t opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this won’t apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

When you contact us, whether via our website or otherwise, you agree that we may reach out to you via LinkedIn or by email, as it is necessary for our legitimate interests (to enable us to broaden our professional network).

6. Cookies

Our website uses cookies in accordance with the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and data protection legislation to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

We will always ask for your consent to use non-essential cookies. You are free to withhold consent to this, but it means that we might not be able to provide the full website experience to you, including some elements of video advertising. If at any time you wish to disable our cookies, you can do so through the settings on your browser, or whenever the pop-up appears on the website (each time you access the website).

7. Disclosures of your personal data

We may disclose your information in the following cases:

• If we want to sell our business, or our company, we can disclose it to the potential buyer
• We can disclose it to other businesses in our group, as defined in the UK Companies Act 2006
• We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety, or rights
• We can exchange information with others to protect against fraud or credit risks.

We may contract with third parties to supply services to you on our behalf. These include:

• Analytics service providers
• Event/campaign management service providers
• Website management service providers
• Information technology and related infrastructure provision
• Email delivery services
• Our auditors and legal advisors.

In addition, our website has a ‘Contact’ function, which enables you to send and for us to receive and reply to your messages and to reply to them. For this, we use Formspree. You can read Formspree’s privacy policy here: https://formspree.io/legal/privacy-policy/

These third parties are known as sub-processors. Where we share your personal data with those sub-processors, they will be bound by confidentiality and data protection obligations. We do this to ensure that your personal data is kept safe and secure.

8. Data security

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure personal data we collect. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business 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.

Our website is hosted by Ghost.org, and its servers are located in Amsterdam, The Netherlands. By using our services, you consent to the transfer and storage of your data on our servers. From time to time, Ghost Foundation may also use third party vendors and hosting partners to store data. These third party vendors and hosting partners may be located in a country other than The Netherlands or your country of residence. By using our services, you also agree to us sharing data from you with our third party vendors and hosting partners so that we can provide you with our services.

In addition to this, we use Google cloud services to host personal data collected by us. Google’s cloud services employ industry standard security including encryption in transmit and at rest and ISO/IEC27001/27017/27018/27701, SOC 1/2/3, PCI DSS, and FedRAMP certifications. For more information, please refer to: https://cloud.google.com/security/. It is important to note that personal data is encrypted between your device and any external host storage we use.

If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the ICO, to limit the extent of the breach and to prevent a further reoccurrence.

9. International transfers

We may transfer your personal data outside of the United Kingdom or the European Economic Area (EEA) where we engage third parties to provide services on our behalf, such as to receive services or deal with payment. Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented, such as only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or the EEA.

10. 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. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. The appropriate retention period will vary depending on the type of personal data collected.

11. Your legal rights

Under certain circumstances, you have rights under the data protection legislation in relation to your personal data:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

You won’t have to pay a fee to access your personal data (or to exercise any of the other rights), but we can charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or we can refuse to comply in these circumstances.

We may need you to provide evidence of your identity as a security measure and we may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month, but it could take 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 and keep you updated.

12. Third party links

This policy only relates to our website. We might have links on/within our website to other websites - these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.

13. Changes to this policy

We can update this policy from time to time as laws change or as our website or services change. If we make material changes to this policy, and we need your consent to those changes, we will contact you by email to do so.