Ogilvie Advisory Ltd T/A The Islay Wellness Academy - Privacy Notice
Effective date: 1st August 2022
This policy explains:
- who we are
- why we collect personal data about you
- where we get it from
- how we use it;
- how we store and secure it;
- how long we keep it;
- your rights; and
- how to complain about our use of personal data.
WHO WE ARE
Ogilvie Advisory Ltd T/A The Islay Wellness Academy (“we”, “us”) is a limited company registered in Scotland
Company number: SC540042
Registered office address: 358 Riverside Drive, Dundee, DD1 4XD
We act as a ‘controller’ of the personal data that you give to us. We are registered with the UK’s Information Commissioner’s Office, registration number ZB358894.
WHY WE COLLECT PERSONAL DATA
To serve you, we need to store your name and contact details. We also keep track of your progress through the programme for two reasons: so you can resume where you left off, and so we can test which parts of the programme are effective and which might need improvement.
We never sell personal data to anyone for any purpose. We will not give your data to others for their own use without your permission.
WHERE WE GET YOUR PERSONAL DATA FROM
We collect personal data about you directly from you.
HOW WE USE YOUR PERSONAL DATA
Under the law, we must process your data lawfully, fairly, and transparently. Depending on our purposes for using data, we rely on one of three two bases, as follows:
|
Type of personal data |
Why we process this data |
Our legal bases |
|
Contact details: potential customers |
Respond to enquiries |
Our legitimate interests |
|
Contact details: customers |
Provide services you buy from us Customer service, direct marketing to existing customers |
To perform our contract with you Our legitimate interests |
|
Payment details |
Collect payment from you. |
Our legitimate interests |
|
Details about when and why you contacted us (or we contacted you), including emails and customer service notes |
Customer service. |
Our legitimate interests To perform our contract with you |
|
Which modules you access and when you access them |
You can resume the programme where you left off. Product improvement: we can assess how each module is performing. |
Our legitimate interests |
|
Comments you post in response to content or discussions. |
Provide discussion and feedback mechanisms for our customers. |
Our legitimate interests |
|
IP address (and geolocation derived from the IP address) when you log in |
Analyse webpage usage. Improve content and customer experience. |
Our legitimate interests |
Some of your legal rights will depend on which legal basis we are relying on for processing. Please see the Your Rights section below.
DIRECT MARKETING
If you are an existing or previous client, we may email you to promote goods or services that are similar to what you have bought from us before. You have the right to opt out of receiving these emails at any time by:
- contacting us by email at [email protected]; or
- using the ‘unsubscribe’ link at the bottom of the email.
If you have never bought anything from us, we will only send you marketing emails if you have explicitly opted in to our marketing list in advance.
We never sell personal data to anyone for any purpose. Also, we will not give your data to others for their own use without your permission.
HOW WE STORE AND SECURE PERSONAL DATA
We hold limited personal data at our office in Scotland. Only those with a genuine business need have access to your data, and all are under a legal duty of confidentiality.
We also use the following external services to store and process data on our behalf:
|
Service provider |
Type of processing |
Where data is stored |
|
Microsoft OneDrive |
general file storage |
UK |
|
Dropbox |
General |
USA |
|
Kajabi |
platform that hosts the service we provide |
USA |
|
PayPal |
payment processing |
USA |
|
Stripe |
payment processing |
USA |
We only store data with a provider if we are satisfied they protect it with robust policies and cybersecurity measures.
All external processors have contracts with us. They are required not to reuse your personal data for their own purposes unless they are also listed as a controller within this policy.
TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK
We store and process data in the UK. However, sometimes we need to send personal data outside the UK, such as where:
- one of our service providers is located outside the UK; or
- you are located outside the UK.
These transfers are subject to special rules and safeguards under UK law.
If you would like further information about data transfers to other countries, please contact us.
HOW LONG WE KEEP PERSONAL DATA
We will keep your personal data after we have finished advising or acting for you or your organisation.
We will do so for one of these reasons:
- to respond to any questions, complaints made by you or on your behalf;
- to pursue or defend legal claims;
When it is no longer necessary to retain your personal data, we will delete or irreversibly anonymise it. If you have any questions about how long we keep your information for, please contact us using the details below.
YOUR RIGHTS
You can exercise any of your rights in this section free of charge by contacting us by email at [email protected].
You can ask us to:
- provide you with a copy of your personal data;
- correct mistakes in data we hold about you;
- delete your personal data from our records (subject to some exceptions according to law – if any of these apply we will explain that to you at the time);
- restrict the processing of your data in some circumstances, such as if you dispute the accuracy of the data; and
- in certain situations, provide you with a copy of the personal data you provided to us in an easily portable format.
You can object:
- at any time to your personal data being processed for direct marketing;
- to our continued processing of your personal data in some other situations, such as where we rely on “legitimate interest” as a legal basis for processing.
If we are relying on your consent (permission) to use your personal data, you can withdraw your consent any time. However, in some cases if you withdraw consent:
- we may still process your personal data without your consent as required or permitted by law, for example to defend our legal rights or to obey a legal requirement to keep the data; or
- we may no longer be able to provide you with goods or services (we’ll let you know when this would be the case)
For further information on your rights, please contact us. You can also review the Information Commissioner’s Office webpage on Individual Rights by clicking here: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
COMPLAINTS
You can complain about our use of personal data to the Information Commissioner on their website (www.ico.org.uk/concerns) or by calling +44 303 123 1113. However, we would appreciate the chance to deal with your concerns before you approach the Information Commissioner so please contact us in the first instance.
CHANGES TO THIS PRIVACY POLICY
This privacy policy was published on 1st August 2022. We periodically review this policy and we will publish any changes on this website.
HOW TO CONTACT US
Please contact us by post or email if you have any questions about either this policy or the information that we hold about you:
Ogilvie Advisory Ltd358 Riverside DriveDundeeUnited KingdomDD1 4XD
