Goliath Sourcing Academy Ltd
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;]
“Our Site” means this website, www.goliathsourcingacademy.com
“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
“We/Us/Our” means Goliath Sourcing Academy, a limited company registered in England under 09331953 whose registered address is c/o J S White & Co 25-29 Sandy Way, Yeadon, Leeds, West Yorkshire, LS19 7EW and whose main trading address is Kemp House, 152-160 City Rd, London EC1V 2NX.
2. Information About Us
2.2 Our data protection officer is B Lazarus who can be contacted at firstname.lastname@example.org
2.3 We are on the Data Protection Register (Ref: ZA363868) through the Information Commissioners Office (ICO)
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
4.2 contact information such as email addresses and telephone numbers;
4.3 business/company name;
4.4 demographic information such as post code, preferences and interests;
4.5 financial information such as credit / debit card numbers;
4.6 IP address (automatically collected);
4.7 web browser type and version (automatically collected);
4.8 operating system (automatically collected);
4.9 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 We use your data to provide the best possible website experience and services to you. This includes:
5.2.1 Providing and managing your Account;
5.2.2 Providing and managing your access to Our Site;
5.2.3 Personalising and tailoring your experience on Our Site;
5.2.4 Supplying Our services to you;
5.2.5 Personalising and tailoring Our products and services for you;
5.2.6 Responding to communications from you;
5.2.7 Supplying you with email content e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the ‘Unsubscribe’ link in any and every email We send You.
5.2.8 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.
5.4 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 AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products AND/OR 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, as amended in 2004, 2011 and 2015.
5.5 Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.
5.6 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do We Store Your Data?
6.2 Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer 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 EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
6.4 Steps We take to secure and protect your data include:
6.4.1 Using appropriate technical and organisational steps, and will store it on our database within a secure network.
6.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
7.2 We may contract with third parties to supply products and 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.
7.3 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 information. 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.
7.4 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
8.2 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.
9. How Can You Control Your Data?
9.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact us for more details at email@example.com, or using the contact details below in section 14.
13. Summary of Your Rights under GDPR
13.1 the right to request access to, deletion of or correction of, your personal data held by Us;
13.2 the right to complain to a supervisory authority;
13.3 be informed of what data processing is taking place;
13.4 the right to restrict processing;
13.5 the right to data portability;
13.6 object to processing of your personal data;
13.7 rights with respect to automated decision-making and profiling (see section 14 below).
14. Automated Decision-Making and Profiling
14.2 The right described in section 14.1 does not apply in the following circumstances:
a. The decision is necessary for the entry into, or performance of, a contract between the You and Us;
b. The decision is authorised by law; or
c. You have given you explicit consent.
14.3 Where We use your personal data for profiling purposes, the following shall apply:
a. Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b. Appropriate mathematical or statistical procedures will be used;
c. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.