Privacy Policy – Focused Propositions

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that data.

1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.  These cookies help us to analyse traffic to see things like the effectiveness of our internet content/advertising in driving people to our website.

1.4 Our website incorporates privacy controls which affect how we will process your data collected when you download a paper or sign up to our newsletter. By using the privacy controls on these forms, you can specify whether you would like to receive these direct marketing communications. You can also opt-out here: https://focusedpropositions.com/newsletter-unsubscribe/

1.5 In this policy, “we”, “us” and “our” refer to Focused Propositions Limited. We provide services to businesses and their employees. For more information about us, see Section 13.

2. Credit

2.1 This document was created by adapting a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

3.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and identifying how you found our site. The legal basis for this processing is our legitimate interests, namely improving our website, the relevance of its content, and the effectiveness of our traffic driving campaigns.

3.3 We may process your account data (“account data“). The account data may include your name, job title and business email address or telephone number. The account data may be processed for the purposes of communicating with you and maintaining back-ups of our databases. The legal basis for this processing is consent to communication OR legitimate interests, namely the proper administration of our business and the performance of a contract (or negotiation of one) between you and us.

3.4 We may process your personal data that is provided in the course of the delivery of our services (“service data“). The service data may include your name, job title, business email and telephone number, and any information about your business or role which you provide to use in a telephone call or by email. The source of the service data is you or your employer. The service data may be processed for the purposes of providing our services, communicating with you and maintaining back-ups of our databases. The legal basis for this processing is our legitimate interests, namely the performance of a contract between your company and us and/or taking steps, at your request, to enter into such a contract.

3.6 We may process information that you post for publication on our website or in our advertising (“publication data“). The publication data may be processed for the purposes of enabling such publication to promote our services. The legal basis for this processing is consent.  You are the source of this data.

3.7 We may process information contained in any enquiry you submit to us regarding our services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you in line with your enquiry. The legal basis for this processing is legitimate interests, namely our interest in the proper administration of our business and communication with you.

3.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us (“transaction data“). The transaction data may include your contact details, your company’s bank details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and our legitimate interests, namely our interest in the proper administration of our business.

3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications, papers, podcasts and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent and the performance of a contract between you and us.  You can unsubscribe at any point here:  https://focusedpropositions.com/newsletter-unsubscribe/

3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business and communications with users.

3.11 We may process data relating to your customers, where you provide that to us.  We will use this data to undertake surveys on behalf of your Company and to collect feedback about your services and brand. The legal basis for this processing is the performance of a contract between you and us.

3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.15 Please do not supply any other person’s personal data to us unless we prompt you to do so.

4. Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2 We have clients in the United States of America. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country. Transfers of data provided by and to clients will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

5.3 The hosting facilities for our website are situated in the UK.

5.4 You acknowledge that personal data that you submit for publication through our website or services (such as a comment on an article or review of our services) may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) All data relating to the delivery of contracted services (or discussions relating to entering into a contract with us) will be retained for a minimum period of 7 years and a maximum period of 10 years after we last provided contracted services to you.  This includes data relating to your company, employees and also your customers (where you have asked us to contact them to research their views on your company and your services).

(b) Personal and contact data for marketing purposes will be retained for a minimum period of 2 years and a maximum period of 3 years. After this period, consent will need to be renewed or the data destroyed.

6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of changes to this policy [by email or through the private messaging system on our website].

8. Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. You should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to ask whether or not we process your personal data and, where we do, give you access to the personal data, together with certain additional information. You may instruct us to provide you with any personal information we hold about you by emailing hello@focusedpropositions.com. Provision of such information will be subject to:

(a) the payment of an admin fee (currently fixed at GBP 10); and

(b) the supply of appropriate evidence of your identity.

8.4 We may withhold personal information that you request only to the extent permitted by law.

8.5 You have the right to have any inaccurate personal data about you rectified, taking into account the purposes of the processing.  In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure which includes where processing is necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 You may instruct us at any time not to process your personal information for marketing purposes. In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes (where you are in a corporation).  You can opt out here: https://focusedpropositions.com/newsletter-unsubscribe/

8.6 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.7 Withdrawal of consent to process your data will not affect the lawfulness of processing before the withdrawal.

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.  Our site uses both.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for:

(a) analysis – we use cookies to help us to analyse the use and performance of our website and services including how you got to our site and whether you clicked on any of our internet advertising.  See 11 below.

(b) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (whether you consented to the use of cookies on our site).  See 12 below.

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at https://www.google.com/policies/privacy/.

11.3 We use LinkedIn to promote our services and content from our site. This service uses cookies to track the effectiveness of this advertising in driving people to our website. You can view the privacy policy of this service provider at https://www.linkedin.com/legal/privacy-policy

11.4 We use Yoast to track the effectiveness of our SEO. This service uses cookies to track whether search engines are able to index our site and the effectiveness of content on our webpages. You can view the privacy policy of this service provider at https://yoast.com/privacy-policy/

12. Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites and if you block cookies, you will not be able to use all the features on our website.

13. Our details

13.1 This website is owned and operated by Focused Propositions Limited.

13.2 We are registered in England and Wales under registration number 10542522 and our registered office is at 151 Richmond Road, Twickenham, TW1 3AT, UK.

13.3 Our principal place of business is at that address.

13.4 You can contact us:

(a) Using our website contact form – https://www.focusedpropositions.com/contact/

(b) By email – hello@focusedpropositions.com

14. Data protection officer

14.1 Our data protection officer’s contact details are: Jill Pringle, Director.  Tel: 07575 148618.  Email: jill@focusedpropositions.com

Focused Propositions Limited  Privacy Policy April 2018