Privacy policy

Introduction

This website is owned and operated by Barnham Marketing (Barnham Marketing” or “we” or “us”). Barnham Marketing is committed to your privacy and adheres to the UK General Data Protection Regulations (UK GDPR) and the Data Protection Act 2018 to ensure protection of your personal data. We also adhere to the Privacy and Electronic Communications Regulations (PECR) to protect your

privacy rights when carrying out direct marketing activities. The UK GDPR applies wherever we process personal information. Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online services. PECR covers marketing by phone, fax, email text or any other type of electronic mail. Our business activities comply with both the UK GDPR and the PECR.

This Privacy Notice (“Notice”) explains our marketing processes, information collection and disclosure practices, and goes into detail about who we are, what information we might collect about you, how we might use, store and share that information and finally details your rights and choices in relation to that personal information.

Scope

This Notice covers the consulting services offered by Barnham Marketing and the personal information we collect as a result of the provision of those services. This Notice applies only to the actions of Barnham Marketing Ltd and users with respect to this website. It does not extend to any websites that can be accessed from this website including, but not limited to, any links we may provide to social media websites.

Personal Information

Information we collect falls into one of two categories: ‘voluntarily provided’ information and ‘automatically collected’ information.

Voluntarily provided information refers to any information you knowingly and actively provide us when using or participating in any of or services or promotions. Automatically collected information refers to any information automatically sent by your devices in the course of accessing or products and services.

Personal information you provide to us:

Identity Information
Including first name, last name, title
Contact Information – email address, telephone number
Transaction Information – billing address, some payment information that may include payment card details
Usage Information– including some information about how you use our website andservices

Usage Information

When you visit our website, our servers may automatically log the standard data provided by yourweb browser. It may include your device’s Internet Protocol (IP) address, your browser type andversion, the pages you visit, the time and date of your visit, the time spent on each page, and otherdetails about your visit.Additionally, if you encounter certain errors while using the site, we may automatically collect dataabout the error and the circumstances surrounding its occurrence. This data may include technicaldetails about your device, what you were trying to do when the error happened, and other technicalinformation relating to the problem. Please be aware that while this information may not be personally identifying by itself, it may bepossible to combine it with other data to personally identify individual persons.

How and why we use your Personal Information

We will only collect and use your personal information when we have a legal right to do so. We will always collect and use your personal information lawfully, fairly and in a transparent manner. In using our services and our website, you are likely to provide us with some or all of the personalinformation described above. When making an enquiry using the sign up form on the website you arelikely to provide us with identity information which will be used to respond to you.

In order to schedule a consultation with us and pay for a consultation (where fees apply), we will needto collect your identity information and some transaction information in order to successfully scheduleyour consultation and pay the associated fees. In addition to the above, we may collect, hold, use and disclose information for the followingpurposes:

To provide you with our website’s core features and services;
To operate and improve our website, associated applications, and associated social mediaplatforms;
For advertising and marketing.In order to help you protect yourself and your information, we encourage you to provide only thatinformation that is necessary for using our website or services.

Our lawful bases for processing your personal information depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:

Consent Form You: Where you consent to the collection and use of your personal information for a specific purpose. You may withdraw your consent at any time using thefacilities we provide; however, this will not affect any use of your information that has already taken place.
Performance of a Contract or Transaction: Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you.
Our Legitimate Interests: Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.
Compliance with Law: In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations.

Children’s Policy

If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian’s consent to process your personal information for that specific purpose. We do not aim any of our products or services directly at children under the age of 13 and we do notknowingly collect personal information about children under 13.

Marketing Activities

Where our marketing is aimed at an individual including where we send emails to a corporate email address that contains an individual’s name, we may require your consent before we can send you a marketing message. PECR rules require that consent must be knowingly and freely given, clear and specific. In specific instances where we rely on consent to send you marketing messages, we will request such consent from you, for example by asking you to tick an opt-in box confirming you are happy to receive such messages. Where our marketing is directed towards a business, the PECR rules on marketing by electronic mail do not apply.

However, we will still provide relevant details of who we are and always give a business the option to unsubscribe from our emails. Sometimes, we will rely on an exemption under the PECR rules that means we do not require your consent to send you electronic marketing. The exemption applies to existing customers whose details are automatically provided. Where we rely on this exemption, you will always be offered the opportunity to refuse or opt out of the marketing in any communication we send you.

Third Party Processing

We use the services of third parties in order to help us process your information from time to time. When scheduling consultations or when sending you communications such as newsletters, these third parties help us to carry out these functions safely and effectively.

Your personal information is shared with these third parties only when strictly necessary in order to help us deliver our services to you.

Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

Our Details

For any questions or concerns regarding your privacy, you may contact us using the following details:

Email: [email protected]

Retention of your data

We will hold your personal information only where we have an ongoing lawful basis or legal need todo so. The length of time we hold personal information for depends upon the purpose for which it was collected. As an example, if you have provided us with personal information such as an email address when contacting us about a specific enquiry, we may retain this information for the duration of your enquiry remaining open as well as for our own records (for a limited period of time) so we may effectively address similar enquiries in future. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you. However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposesSECURITY OF

Your Information

We have appropriate security measures in place to prevent personal information from accidental loss, unlawful access or any unauthorised use. We ensure that in providing our services to you, your information is only processed in an authorised manner and offered the appropriate protection at all times whilst it is under our control.Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security.

Disclosure of your Information

During the course of business, it may be necessary to disclose some personal information to third parties including:

Our parent, subsidiary or affiliate of our company (where we have one);
Third-party service providers including IT service providers, debt collectors, operational service providers, marketing or advertising providers, professional advisors, and payment systems operators;
Our employees, contractors, subcontractors, agents and/or related individuals or entities who assist us in providing information, products, services or direct marketing to you;
Our existing or potential agents or business partners;
Credit reporting agencies, courts, tribunals, law enforcement, and regulatory authorities;
An entity that buys, or to which we transfer all or substantially all of our assets and business;
Otherwise where we have your consent or are otherwise legally permitted to do so.

The privacy of your information is important to us and as such we ensure that we only share your information with third parties where this is a need to do so. In the event that we need to share your information as a result of our assets being acquired or in the unlikely event that we go out of business or enter bankruptcy and to the extent permitted by applicable law, you acknowledge that such transfer of information may occur.

Your Rights and Choices

By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our website or the products and/or services offered on or through it. Under the UK General Data Protection Regulation, you have a number of important rights and choices as to how your personal information is treated.

You can ask for copies of your personal information;
You can ask us to rectify inaccurate or incomplete personal information;
You can ask us to erase your personal information;
You can ask us not to use your personal information for marketing;
You can ask us to restrict the processing of your personal information;
You can object to the processing of your personal information;
You can ask that we transfer your personal information to another organisation or to you
You can complain about our processing of your personal information; and
To the extent that the legal basis of our processing of your personal information a is consent, you can withdraw that consent.

Under the PECR rules, if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below or unsubscribing using the link in the messages we send you. We may need specific information from you to help us confirm your identity. We will not discriminate against you for exercising any of your rights over your personal information.

Complaints: If you believe that we have breached a relevant data protection law or regulation and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. As detailed above, you also have the right to contact a regulatory body or data protection authority in relation to your complaint. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects here. You may exercise any of your rights in relation to your personal information by sending us an email at [email protected].

Cookies

We use cookies to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our cookie policy for further information.

Changes to this Policy

We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.If you do not agree to the changes or how we use your personal information, you should stop using our services and get in contact with us to delete your account and personal information.

Additional Disclosures For Australian Privacy Act Compliance (AU)

International Transfers of Personal Information

Where the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act. You acknowledge that if any such third party engages in any actor practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act, and you will not be able to seek redress under the Privacy Act.

Additional Disclosures For UK GDPR Compliance

Data Controller / Data Processor

The UK GDPR distinguishes between organisations that process personal information for their own purposes (known as “data controllers”) and organisations that process personal information on behalf of other organisations (known as “data processors”). Barnham Marketing is a Data Controller with respect to the personal information you provide to us.

International Transfers Outside Of The European Economic Area (EEA)

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of bindingcorporate rules or other legally accepted means.

Additional Disclosures For California Compliance (US)

Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organisations for their marketing purposes. To make such a request, please contact us using the details provided in this Notice with “Request forCalifornia privacy information” in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of personal information we revealed to other organisations for their marketing purposes in the last calendar year along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code. CCPA-PERMITTED

Financial Incentives

In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

California Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act: For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section.

We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.

Right to Know and Delete

If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

The categories of personal information we have collected about you;
The categories of sources from which the personal information was collected;
The categories of personal information about you we disclosed for a business purpose or sold;
The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
The business or commercial purpose for collecting or selling the personal information; and
The specific pieces of personal information we have collected about you.

To exercise any of these rights, please contact us using the details provided at the bottom of this Notice.

Shine the Light

If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own direct marketing purposes. To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.