We are Bill Harvey Associates Limited (“BHAL”), a company registered in England and Wales under company number 04550257 and with our registered office at Gairloch, Hensleigh Drive, Exeter, Devon, EX2 4NZ.
BHAL respects your privacy. All information you give us is held with care and security.
For the purposes of the Data Protection Act 1998, Bill Harvey Associates Limited is the 'data controller' (ie the company who is responsible for, and controls the processing of, any personal data you submit to us).
Collection and use of information
We will use the personal information provided to us in order to:
· process orders submitted by you;
· customize the service we provide to you;
· administrate or otherwise carry out our obligations in relation to any agreement you have with us;
· verify your identity (e.g. if you participate in any promotions administered by us);
· anticipate and resolve any problems with any goods or services supplied to you;
· carry out market research and surveys and track sales data;
· send you our newsletters, where these are requested by you;
· send you our email courses, where these are requested by you;
· track your engagement with us, including through our website, articles and newsletters;
· understand how you use our products and services; and
· contact you by telephone and send you follow-up communications relating to your use of our products and services, including samples and demonstration versions of software.
We may also ask you for other optional information such as what sort of equipment/device/software you use and what subjects interest you. If you choose to give us this information, we will use it to help us to provide you with the best possible service that is personalized to your needs and preferences.
Although we do not make it compulsory to give us every item of information we ask for, the more information volunteered by our customers (and the more accurate it is), the better we can match our services to the needs of our customers.
What information do we collect?
We collect the following data:
· Postal address
· Email address
· Phone number
· Details of usage of our website
· Emails sent to and received from you
· Attendance of events we organise (for example courses and seminars)
· Purchase details
Third-Parties and their sites
BHAL and Obvis Limited (“Obvis”) (http://www.obvis.com/) are sister companies that work closely together. Indeed they employ largely the same people. As such, sharing of data between these companies is unavoidable. The Obvis and BHAL privacy policies will be maintained in parallel.
Some of our services make use of hosted tools, hosted data storage and payment services provided by third parties. Where this is so, any of your personal information stored by such third parties shall be subject to their own privacy provisions unless otherwise specified in this policy.
Whilst we choose our business partners carefully, unfortunately we cannot be responsible for their privacy policies and practices or those of other sites that you access using links from our site. Therefore we recommend that you check the policy of each site you visit.
We also make use of third party services in order to provide a high quality service to you. Note that several of these services are located out of the EEA. The transfer of data outside the EEA is discussed below.
We do not record any calls.
Log files and analytics
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyse trends in the aggregate and administer the site.
We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to help us understand this information. This requires us to provide some of the details we automatically gather (e.g. IP addresses) to Google Analytics. We use the “anonymizeIp” feature of Google Analytics, which causes Google to store only part of your IP address.
If you wish to, you can prevent Google from collecting data for us or any other website that uses Google Analytics by installing the browser plug-in available here: https://tools.google.com/dlpage/gaoptout?hl=en-GB.
Please note that if you do not prevent Google Analytics from collecting data for us as above then some information relating to you will be disclosed to Google Analytics and will be held by them in accordance with their own privacy policies available here: https://www.google.com/policies/privacy/. We recommend that you check the Google Analytics privacy policies to make sure you are happy with their terms.
Session cookies are used when users log in to the website. BHAL will use such cookies to identify unique users of our websites. They are not cross-referenced with any other information such that an individual person could be identified.
The following table gives details of the cookies we or our service providers may ask your browser to set.
|Crumb||Session||Security - prevents cross-site request forgery attacks|
|RecentRedirect||30 minutes||Protects against site mnisconfiguration causing an endless redirect.|
|squarespace-popup-overlay||Persistent||Prevents a promotional pop-up from displaying once you have dismissed it|
|squarespace-announcement-bar||Persistent||Prevents an announcement bar from displaying once you have dismissed it|
|__ga||2 years||Used to distinguish users|
|__gid||24 hours||Used to distinguish users|
|_dc_gtm_UA-32408614-2||1 minute||Used in implementation of analytics system (to throttle request rate)|
|__drip*||Used to implement pop-up offer and mailing list subscription forms, and remember when you dismiss these|
Disabling/Enabling Cookies – users have the ability to accept or disable cookies by modifying the settings in their browser. Disabling cookies, however, may mean that some functionality may be affected. For further directions on how to disable cookies please visit http://www.allaboutcookies.org/manage-cookies/stop-cookies-installed.html.
In addition to the disclosures referred to elsewhere in this policy, we may disclose your personal data to:
· other companies within our group;
· our agents and service providers for the purposes of fulfilling any contractual obligations we have to you (and only after having ensured that steps have been taken to ensure that your privacy rights continue to be protected);
· law enforcement agencies and/or HMRC in connection with any investigation to help prevent unlawful activity; and
· in accordance with the two ‘products and services’ sections below.
We may also disclose your personal information to a third party either as part of a reorganization or a sale of the assets of BHAL and having ensured that steps have been taken to ensure that your privacy rights continue to be protected.
Other than the disclosures referred to in this policy, we will not disclose any personal information without your permission unless we are legally obliged or entitled to do so (for example, if required to do so by Court order or for the purposes of identifying fraud or other crime).
Information about our products and services
It is very important to us that we provide you with the highest level of service. In order to help us do this, from time to time BHAL may send you, with your consent, details of our products and services which we think may be of interest to you. We will send you this information by email. We will inform you (before collecting your data) and seek your permission if we intend to use your data for such purposes.
You have the right at any time to ask us to stop processing your personal data for direct marketing purposes. You can unsubscribe from any or all of our newsletters by using the 'unsubscribe' option located in each of our newsletter communications. Alternatively you can email us at email@example.com requesting removal.
Third party products and services
If you have given permission, we may contact you by telephone and email to provide information about products and services we think may be of interest to you from other companies (including Obvis), but only if we think these will be of value to you. We will inform you (before collecting your data) if we intend to use your data for such purposes. If you would rather not receive such third party marketing information from us, or you no longer wish to receive it, you can opt out at any time (see below).
We do not sell, rent or loan any identifiable information regarding our customers to any third party for marketing purposes.
Keeping our records accurate
We aim to keep our information about you as accurate as possible. If you would like to review or change the details you have supplied us with, please contact us as set out below.
Information about other individuals
If you give us information on behalf of a third party, you confirm that the third party has appointed you to act on his/her/their behalf and has agreed that you can: give consent on his/her/their behalf to the processing of his/her/their Information; receive on his/her/their behalf any data protection notices; and give consent to the transfer of his/her/their Information abroad (if applicable).
User discussion forums
Obvis/BHAL may make email discussion lists, chat rooms, forums, message boards and/or other news groups available to its users. Any information that is disclosed in these areas becomes public information and you should always be careful when deciding to disclose your personal information.
Keeping your data secure
We will use technical and organisational measures to safeguard your personal data, for example we will store your personal data on secure servers and will use security measures (including data encryption) to protect it.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.
Transfers of your personal information outside of the European Economic Area
Information you provide to us may be transferred by us to our service providers that are situated outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA. If we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.
When you provide information to us you acknowledge and agree that we may transfer your personal data to countries outside the EEA.
Legal basis of our processing
The Data Protection Legislation requires that we have a clear legal basis for processing your personal data. To be open and transparent with you in respect of our use of your personal data, here are the legal bases for our processing:
|Purpose/use||Legal basis||Categories of data|
|To communicate news and information relating to BHAL products and services, educational material, and other material likely to be of interest to subscribers.||Consent||
Information provided when mailing list subscribers sign up (Name, email address, company, location).
Information automatically collected through the Site and email marketing software (history of emails sent and interactions).
|To deliver our products and services, and to respond to queries regarding our products and services||Contract||Information provided when placing an order for a product or service, when asking us to do something in preparation for an order, or collected in the process of fulfilling an order. (Name, email address, office address,|
Automated Decision Making and Profiling.
We do not use your personal data for the purposes of automated decision-making or profiling as those terms’ meanings apply in the context of the Data Protection Legislation. However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
Children's Privacy Protection
Our products and services are developed, marketed and intended for use by businesses only. We do not knowingly engage in any data collection, processing or storage of Users under 18. Our communication, marketing, and sales activities are never aimed at children. In the event that we identify a User who is under-age, we will take all the reasonable measures to prevent this person from continuing their interaction with the Service, and delete the information. If you are 18 or under, please do not access or use our Services without parental consent and supervision. If you are a parent or a legal guardian or concerned third party of a child under 18 who interacted with the Services, please alert us via firstname.lastname@example.org.
We ask that you do not send us, and that you do not disclose, any sensitive personal data about yourself or anyone else (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through BHAL products or otherwise to us.
Changes to this policy
This Policy was last updated on 20 May 2018.
If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, you can do so by sending an email to us at email@example.com or by contacting us at Bill Harvey Associates Limited, Gairloch, Hensleigh Drive, Exeter, EX2 4NZ.
You are entitled to ask for a copy of the information we store about you (for which we may charge a small fee, currently £10). If you wish to exercise this right, you should:
· put your request in writing;
· include proof of your identity and address (eg a copy of your driving licence or passport, and a recent utility or credit card bill);
· attach a cheque in the amount of £10 made payable to Bill Harvey Associates Limited; and
· specify the personal data you want access to, including any account or reference numbers where applicable.