Upshift Consultancy Ltd Cookie and Privacy Policy

October 2020

Cookie Policy

We believe in being clear and open about how we collect and use data related to you. In the spirit of transparency, this policy provides detailed information about how and when we use cookies.

What is a cookie?

Cookies are small files which are stored on a user’s computer. They, and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.

Why do we use cookies?

Yes. As described in our Privacy Policy, Our Site uses cookies and similar technologies to distinguish you from other users of Our Site. This helps us to provide you with a good experience when you browse Our Site and also allows us to improve Our Site.

They are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use. If you have consented to us using cookies then you can withdraw this consent at any time by disabling them as described below.

Cookies also help us keep your account safe. By continuing to visit or use our services, you are agreeing to the use of cookies and similar technologies for the purposes we describe in this policy.

How long do they last?

A number of cookies and similar technologies we use last only for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to Our Site and will last for longer.

What type of cookies do we use?

We use cookies and/or other similar technologies such as tracking GIFs, either alone or in combination with each other to create a unique device ID.

We use the following types of cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They 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 for our legitimate interests of improving 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, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, your choice of language or region).

Disabling cookies

Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this.

The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on Our Site.

If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit:

Other helpful resources

Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information.

For other browsers, please consult the documentation that your browser manufacturer provides.

Privacy Policy

Definitions:

We, Us, Our, Upshift – refers to Upshift Consultancy ltd.

Data Protection Legislation – refers to all applicable privacy and data protection laws including (i) the General Data Protection Regulation ((EU) 2016/679), the Data Protection Act 2018 and any further or additional national implementing laws, regulations and secondary legislation in England and Wales relating to the processing of Personal Data and the privacy of electronic communications, as amended, replaced or updated from time to time, including the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426).

Introduction

Welcome to our privacy policy.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and processes your personal data through your use of this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Upshift Consultancy ltd is the controller and responsible for your personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Changes to this Privacy Notice and your duty to inform us of changes

We keep this privacy policy under regular review. This version was last updated in October 2020.

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 your relationship with us.

Third-party links

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 policy of every website you visit.

Personal Data we receive

Personal data, or personal information, means 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).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity data (including your first name, last name, marital status, title, gender and multi media images);
Contact data (including your billing address, delivery address, email address, telephone contact numbers and social media contact information);
Financial Data (including bank account and payment card details).
Transaction Data (including details about payments to and from you and other details of products and services you have purchased from us).
Technical Data (including 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 this website).
Profile data (includes your username and password, purchase history, preferences, feedback and survey responses);
Usage Data (including information about how you use our website, products and services].
Marketing and Communications data (including your preferences in receiving marketing from us and your communications preferences);
Special Category Data (dietary or access requirements when booking and attending events)

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not generally 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.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

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

Direct interactions.

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

express an interest in us;
Subscribe to emails communication;
request information about Upshift;
attend an Upshift event;
enter a competition, promotion or survey: or give us feedback or contact us.

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 and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources.

We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:
- analytics providers, such as Google based outside the EU;
- search information providers, such as Google based outside the EU;
Identity, Contact and Financial Data from Linked-in
Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from data brokers or aggregators based inside the EU.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
Profile data from Upshift service providers

How your personal data will be used?

We will only use your data in circumstances where the data protection legislation allows us to. Most commonly, we will use your personal data in the following circumstances:

a. Where we need to perform a contract we are about to enter into or have entered into with you;
b. 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;
c. Where we need to comply with a legal obligation;
d. Where we have received your informed and specific consent to do so.

We will only use your data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. We can explain this to you. If we need to use your data for an unrelated purpose, we will notify you and explain why we can do this. Please note that we can process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing

Your personal data may be used to:-

Provide you with a more personalised experience whilst using our website, including advertisements for relevant services and products.
Keep you informed about services and products available to you unless you have told us that you do not wish to receive such information. This could be by email, postal mail, phone or text.

Opting out

You can ask us to stop sending you marketing messages at any time by emailing us on the contact at the end of this document.

Sharing Personal Information

We may disclose your personal information to third parties in the following circumstances:

When a specific service is being provided on our behalf. We will ensure that your personal information is handled as if we were processing it ourselves and under the same terms as this privacy notice. We will only share the minimum information that they need to undertake the service and we will ensure that they keep your information secure.
When we are providing a service on your behalf. This data will be collected through online application forms, which are to be completed voluntarily, and will only be shared with the organisations identified at the time it is received.
When you have requested information about a service or product provided by an affiliated partner and only with your specific consent..

International Transfers

In general personal data collected from you will be stored at a destination within the UK or European Economic Area (EEA). However we may also transfer your data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need 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.

Data retention

How long will we use your personal data for?

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.

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.

By law we have to keep basic information about our members (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being members 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 will 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.

Your Legal Rights

Under the data protection legislation you have a number of rights with regard to your personal data. 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.

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. You also have the right to object where we are processing your personal data for direct marketing purposes. 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 in the following scenarios:

If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

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.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You do not have to pay any fee to request access to the personal information that we hold. However, if your requests become unfounded, repetitive or excessive we have the right to refuse your request or charge you a reasonable fee.

Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Identity and contact details of controller and data compliance advisor

Upshift Consultancy Ltd is the controller of data for the purposes of the data protection legislation.

If you have any concerns as to how your data is processed, or if you have any questions about this privacy policy or our privacy practices more generally, you can contact our data compliance managers at , or you can write to us at:

FAO Data Compliance Manager
Upshift Consultancy Ltd,
Office 10,
Broxburn House,
Silver Street,
Minety,
Wilts,
SN16 9QU