Privacy Policy
1. Data controller(s)
Catherine McManus who offers online marketing services, is the owner of this website https://smallbusinessmarketingconsultant.co.uk/ and is the controller and responsible for your personal data – collectively referred to as “we”, “us” or “our” in this privacy notice. For all data matters contact Catherine McManus on info@smallbusinessmarketingconsultant.co.uk.
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website. We’ll also tell you about your privacy rights and how the data protection law protects you. Please also refer to:
Our cookies policy is HERE.
This, and any other documents referred to on it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
This website is not intended for children and we do not knowingly collect data relating to children.
Third-party links outside of our control
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 notice of every website you visit.
2. Definitions
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
3. The purpose(s) of processing your personal data
We receive, collect and store any information you enter on our website or provide us in any other way. In addition, we collect the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information and purchase history. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We also collect personally identifiable information (including name, email, password, communications); payment details (including credit card information) should you purchase something, comments, feedback, product reviews, recommendations, and personal profile.
We collect your name and email when you subscribe to our newsletter / database so that we can send you news and updates.
We use your personal data for the following purposes:
To provide and operate the Services;
To provide our Users with ongoing customer assistance and technical support;
To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages;
To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
To comply with any applicable laws and regulations.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
Personal data (e.g. name, surname, email address, login, password, comments, feedback, recommendations, personal profile, any communication between you and us, payment details where relevant)
When you conduct a transaction on our website, as part of the process, we collect the personal information you give us such as your name, address and email address. Your personal information will be used for the specific reasons stated above.
You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you :
Apply for our products or services;
Create an account on our website;
Subscribe to our service or publications;
Request marketing to be sent to you;
Take part in competitions and marketing activities both online and offline;
Attend events sponsored or organised by www.smallbusinessmarketingconsultant.co.uk
We use different methods to collect data from and about you including through:
Online and offline forms
Automated technologies or interactions. As you interact with our website, we may 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 HERE for further details
Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below:
Technical Data from the following parties:
(a) Analytics providers [such as Google based outside the EU];
(b) Search information providers
Contact, Financial and Transaction Data from providers of technical, payment and delivery services
Identity and Contact Data from publicly availably sources [such as Companies House and the Electoral Register based inside the EU].
5. What is our legal basis for processing your personal data?
Personal data (article 6 of GDPR)
Our lawful basis for processing your general 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:
Performance of Contract this 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.
Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the 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).
Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
(Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 – Catherine McManus at info@smallbusinessmarketingconsultant.co.uk
We have set out below a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact Catherine McManus at info@smallbusinessmarketingconsultant.co.uk / 07448720859 if you need any more details.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer, a new website member or as a new subscriber to our to mailing list
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(a) Performance of a contract with you (b) 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) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(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 administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
a) Necessary 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)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
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)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
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)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We have established the following personal data control mechanisms:
– Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us [or if you provided us with your details when you entered a competition or registered for a promotion] and, in each case, you have not opted out of receiving that marketing.]
– Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside our company for marketing purposes.
– Opting out
You can ask us or third parties to stop sending you marketing messages at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or] by contacting info@smallbusinessmarketingconsultant.co.uk at any time].
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of [a product/service purchase, warranty registration, product OR service experience or other transactions].]
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). Nor do we collect any information about criminal convictions and offences.
More information on lawful processing can be found on the ICO website.
6. Sharing your personal data
Your personal data will be treated as strictly confidential. We may have to share your personal data with the Internal or External Third Parties set out below.
Our company is hosted on the WordPress platform. WordPress provides us with the online platform that allows us to provide you with our products and services and sell our products and services to you. Your data may be stored through WordPress data storage, databases and the general WordPress applications. They store your data on secure servers behind a firewall.
Google Analytics to help us understand how our customers use the Site–you can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here.
Google Advertising and other Google products. Some of our cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose such as with Google Analytics and Google Advertising. Third-party vendors, including Google, use cookies and/or device identifiers to serve ads across the internet based on someone’s past visits to our website. This basically allows us, as a company, to personalise our ads and communicate with people who have already visited our site and have already shown an interest in what we do (this is called remarketing). You can find out how to opt-out of these Google Analytics Advertising Features by clicking here. You can also opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using your device’s settings.
Please refer to our full policy about cookies here.
Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers 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].
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. How long do we keep your personal data?
Your information will be stored for as long as you are a member, subscriber or interact with our site.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, 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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.]
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so might mean that you are not able to use some of the facilities and services available on the website, such as the ability to purchase items e.g. products/services/events or become a member, which allows you to interact with the website and leave reviews and comments.
a) Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
The right to request a copy of the personal data which we hold about you;
The right to request that we correct any personal data if it is found to be inaccurate or out of date;
The right to request your personal data is erased where it is no longer necessary to retain such data;
[The right to withdraw your consent to the processing at any time, WHERE CONSENT WAS YOUR LAWFUL BASIS FOR PROCESSING THE DATA];
The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact Catherine McManus at info@smallbusinessmarketingconsultant.co.uk
No fee required – with some exceptions
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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
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.
Time limit to respond
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 and keep you updated.
9. Transfer of Data Abroad
Our company is hosted on the WordPress platform. WordPress provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through WordPress data storage, databases and the general WordPress applications. They store your data on secure servers behind a firewall.
We may receive personal data about you from various third parties [and public sources] as set out below:
Technical Data from the following parties:
(a) Analytics providers [such as Google based outside the EU];
(b) Search information providers
Contact, Financial and Transaction Data from providers of technical, payment and delivery services
Identity and Contact Data from publicly availably sources [such as Companies House and the Electoral Register based inside the EU].
10. Automated Decision Making
We do not use any form of automated decision making in our business.
11. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
12. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
13.How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our DATA PROTECTION OFFICER Catherine McManus on info@smallbusinessmarketingconsultant.co.uk
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
Please note – Markel Law owns the copyright in this document
