Privacy Policy

Caretta Associates – Privacy Policy

Introduction

Welcome to Caretta Associates’ privacy policy.

Caretta Associates respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

  1. Important Information and Who We Are

Purpose of this privacy policy

This privacy policy aims to give you information on how Caretta Associates collects and processes your personal data through your use of this website, including any data you may provide through this website when you request a service and through your use of our services.

This website and our services are not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy 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 po9licy supplements other notices and privacy policies and is not intended to override them.

Controller

Caretta Associates is the controller and responsible for your personal data (collectively referred to as “Caretta”, “we”, “us” or “our” in this privacy policy).

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our Data Privacy Manager in the following ways:

Full name of legal entity: Caretta Associates

E-mail address: sandra@caretta.associates

Postal address: 20 Mortlake High Street, London SW14 8JN

Telephone number: +44 [] 203 441 2091

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

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

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 that you visit.

  1. The Data We Collect about You

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 includes first name, family name, date of birth and gender
  • Contact Data includes billing address, email address, LinkedIn URL and telephone number
  • Transaction Data includes details about payments to and from you and other details of products and services that you have purchased from us
  • Technical Data includes 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
  • Usage Data includes information about how you use our website, products, and services

 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 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 our services). In this case, we may have to cancel a service you have from us, but we will notify you if this is the case at the time.

  1. 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 other data] by corresponding with us by phone, email or in person. This includes personal data you provide when you :
  • apply for our services; 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please refer to our cookie policy below for further details:

Technical Data from the following parties:

  1. analytics providers [such as Google based outside the UK] and
  2. search information providers [such as Google Analytics, based outside the UK]
  • Contact Data from providers of technical services [such as Google Analytics, based outside the UK]
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register, based inside the UK.
  • Links to publicly available newsfeeds and social media sites relevant to you and your profile
  1. How We Use Your Personal Data

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

  • When we need to perform the contract, we are about to enter or have entered with you.
  • 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.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 Purposes for Which We Will Use Your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you as a new customer

 

(a)     Identity

 

(b)     contact

 

Performance of a contract with you

 

To provide services to you:

 

(a)     Manage payments, fees, and charges

 

(b)     Collect and recover money owed to us

 

(a)     Identity

 

(b)     Contact

 

(c)     Transaction

 

 

 

(a)     Performance of a contract with you

 

(b)     Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you which will include:

 

(a)     Notifying you about changes to our terms or privacy policy

 

(b)     Asking you to leave a review or take a survey

 

 

(a)     Identity

 

(b)     Contact

 

(c)     Profile

 

(a)     Performance of a contract with you

 

(b)     Necessary to comply with a legal obligation

 

(c)     Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

To enable you to complete a survey

 

(a)     Identity

 

(b)     Contact

 

(c)     Profile

 

(d)     Usage

 

(a)     Performance of a contract with you

 

(b)     Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a)     Identity

 

(b)     Contact

 

(c)     Technical

 

(a)     Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

 

(b)     Necessary to comply with a legal obligation

 

To use data analytics to improve our website, services, customer relationships and experiences

 

 

(a)     Technical

 

(b)     Usage

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and (relevant to develop our business)

 

Marketing

We would like to send you marketing communications from time to time such as a newsletter, link to our blog or possibly our podcasts.  We ask that you opt-in to receive these marketing communications from us which you can amend at any time.  [LINK TO CONSENT OPT-IN].”

Third-party Marketing

We will not share your personal data with any third party for marketing purposes.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies that we use, please refer to our Cookie Policy.

Change of Purpose

We will only use your personal 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required and permitted by law.

  1. Disclosures of Your Personal Data

We may share your personal data with the external third parties described below for the purposes set out in the table above.

External Third Parties

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers acting as processors including lawyers, bankers, auditors, and insurers based in the UK who provide banking, legal, insurance and accounting services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. International Transfers

We do not transfer your personal data outside the UK.

  1. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees 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.

  1. Data Retention

How long will you use my 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 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 must keep basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for tax purposes.

In some cases, 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.

  1. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of your legal rights, please contact us.

No Fee Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need from You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

 YOUR LEGAL RIGHTS

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 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 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 that 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.

COOKIE POLICY

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer which are essential for the website to function properly and which help to provide you with a better online experience. These cookies cannot be switched off and do not store any of your information.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Title

Cookie Name

 Purpose More information
GOOGLE ANALYTICS

Examples of purposes for which a cookie may be used:

This cookie enables us to: monitor how many visitors we have and where they are referred from

(a) Estimate our audience size and usage pattern.

(b) Recognise if you are a returning visitor.

(c) To estimate our referred visitors and our Google organic visitors

 TRAFFIC DATA

We also use “analytical” cookies, through Google Analytics (Google LLC) which allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily. Google utilises the data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.

Personal Data processed:  tracker and usage data only.

Place of processing – USA by Google LLC.

 We do not use cookies for commercial and advertising messages.

To remove or prevent cookies being stored on your computer in the future, please refer to your internet browsers instructions.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.