PRIVACY NOTICE

Polished PA
Privacy Notice 

The purpose of this notice is to explain to you how we control, process, handle and protect your personal information through the business and while you browse or use this website. If you do not agree to the following notice you may wish to cease viewing / using this website, and or refrain from submitting your personal data to us.

Key definitions:
• "I", "our", "us", or "we" refer to the business, Polished PA.
• "you", "the user" refer to the person(s) using this website.
• GDPR means General Data Protection Regulation.
• PECR means Privacy & Electronic Communications Regulation.
• ICO means Information Commissioner's Office.
• Cookies mean small files stored on a user’s computer or device.

Key principles of GDPR:
Our privacy notice embodies the following key principles; (a) Lawfulness, fairness and transparency, (b) Purpose limitation, (c) Data minimisation, (d) Accuracy, (e) Storage limitation, (f) Integrity and confidence, (g) Accountability.

Our contact details 
Name: Marissa North
Phone Number: 07944 374 018
E-mail: marissa@polishedpa.co.uk
Website: www.polishedpa.co.uk 

What type of information we have 
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
• name;
• business/company name;
• job title;
• profession;
• contact information such as email addresses and telephone numbers;
• demographic information such as post code, preferences and interests;
• IP address;
• web browser type and version;
• operating system;
• a list of URLs starting with a referring site, your activity on our Site, and the site you exit to.
Sensitive Data
• We do not collect any Sensitive Data about you. Sensitive data refers to data that 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 do not collect any information about criminal convictions and offences.

How we get the information and why we have it
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
• order our products or services;
• create an account on our site;
• subscribe to our service or publications;
• request resources or marketing be sent to you;
• enter a competition, prize draw, promotion or survey; or
• give us feedback.
We also receive personal information indirectly, from the following sources in the following scenarios:
• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies;
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below: 
• analytics providers such as Google based outside the EU;
• advertising networks such as Facebook based outside the EU.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are: 
(a) Your consent. 
(b) We have a contractual obligation.
(c) We have a legal obligation.
(d) We have a legitimate interest.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You are able to remove your consent at any time. You can do this by contacting marissa@polishedpa.co.uk

What we do with the information we have
We use the information that you have given us in order to:
1. Provide and manage your access to our Site;
2. Personalise and tailor your experience on our Site;
3. Supply Our services to you (please note that we require your personal data in order to enter into a contract with you);
4. Personalise and tailor our services for you;
5. Reply to emails from you;
6. Supply you with emails that you have opted into (you may unsubscribe or opt-out at any time);
7. Analyse your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience.
8. With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone, text message and/or post with information, news and offers on our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
We may sometimes contract with third parties to supply services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
Please note, that the transmission of information via the internet is not completely secure and, although we will take steps to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via the Website – any transmission is therefore at your own risk.

How we store your information 
Your information is securely stored in the UK. 
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.
In some circumstances you can ask us to delete your data: see 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.

Your data protection rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information. 
Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 
Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances. 
Your right to object to processing - You have the the right to object to the processing of your personal data in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at marissa@polishedpa.co.uk if you wish to make a request.

Sponsored links, affiliate tracking & commissions
Our website may contain adverts, sponsored and affiliate links on some pages. These are typically served through our advertising partners or are self-served through our own means. We only use trusted advertising partners who each have high standards of user privacy and security. However we do not control the actual adverts seen / displayed by our advertising partners. Our ad partners may collect data and use cookies for ad personalisation and measurement. Where ad preferences are requested as 'non-personalised' cookies may still be used for frequency capping, aggregated ad reporting and to combat fraud and abuse.
Clickable sponsored or affiliate links may be displayed as a website URL or as a titled text link.
Clicking on any adverts, sponsored or affiliate links may track your actions by using a cookie saved to your device. Your actions are usually recorded as a referral from our website by this cookie. In most cases we earn a very small commission from the advertiser or advertising partner, at no cost to you, whether you make a purchase on their website or not.
We use advertising partners in these ways to help generate an income from the website, which allows us to continue our work and provide you with the best overall experience and valued information.
If you have any concerns about this we suggest you do not click on any adverts, sponsored or affiliate links found throughout the website.

Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third-party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences.
Our EMS provider is Mailchimp. We hold the following information about you within our EMS system;
• Email address
• I.P address
• Subscription time & date

What Happens If Our Business Changes Hands?
• Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Notice, be permitted to use that data only for the same purposes for which it was originally collected by us.
• In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

How to complain
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:            
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113

Share by: