INTRODUCTION
This Privacy Notice is provided by Private entrepreneur Krasnobrizhyi Volodymyr (registered number 21190000000036978), whose registered office is at 22 Snizhna Str., Ivano-Frankivsk, Ukraine, 76019 and which trades as 'Krasnobrizhyi.com', 'Signs4sense.com', 'Sales4Progress.com' (plus such other potential trading names as may be used from time to time) (referred to as we, us or our).
We respect your privacy and are committed to protecting your personal data.
This Privacy Notice is intended to inform you as to how we look after your personal data – however you interact with us (including via use of our web-site(s) – and – regardless of where you visit any of them from) and to tell you about your privacy rights and how the law protects you. Please note that some of our websites may collect and process different data to others. Please check the privacy notice for the specific website you are using.
This Privacy Notice has been prepared in plain English (and is provided with 'Headings' with the aim that you can easily review the specific areas set out below).
Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This Privacy Notice aims to give you information on how we collect and process your personal data, including any data you may provide through use of our website(s) when you purchase a service (or sign up to any of our newsletter(s), or take part in a competition).
Our website(s) are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Notice (together with any other Privacy Notice or fair processing notice we may provide 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 Notice supplements the other notices and is not intended to override them.
Controller
We are the controller and responsible for your personal data.
PE Krasnobrizhyi is our data privacy manager . He ais responsible for overseeing questions in relation to this Privacy Notice.
If you have any questions about this Privacy Notice, including any requests to exercise your rights, please contact our data privacy manager by an email sent to:-
volodymyr@krasnobrizhyi.com
Changes to the Privacy Notice 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
Our website(s) 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 any of our website(s), we encourage you to read the Privacy Notice of every website that you visit.
2. 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 including first name, last name, title, date of birth and gender.
• Contact Data including email address and telephone number.
• Technical Data including internet protocol (IP) address, 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 our website(s).
• Usage Data including information about how you use our website(s), products and services.
• Marketing and Communications Data including your preferences in receiving marketing from us and third parties and your communication preferences.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.
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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. 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 Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
• Automated technologies or interactions. As you interact with any of our website(s), we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties (and public sources) based both inside and / or outside the EU – such as those as are set out below:
• Technical Data from the following parties:
o analytics providers;
o advertising networks; and
o search information providers.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
4. 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:
• Where we need to perform the contract we are about to enter into or have entered into 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 or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or electronic 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.
Please 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.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may establish a privacy centre where you can view and make certain decisions about your personal data use or the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us (or if you provided us with your details when you entered a competition or registered for a promotion) and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside of us (or our group of companies) for marketing purposes.
Opting out
You can ask us (or third parties) to stop sending you marketing messages at any time by
• accessing any privacy centre accessible from our website(s) and checking or unchecking relevant boxes to adjust your marketing preferences; or
• by following the opt-out links on any marketing message sent to you; or
• by contacting us (at any time).
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
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 our website(s) may become inaccessible or not function properly. For more information about the cookies we use, please see 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 obtain 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 or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Internal Third Parties (within the meaning – as set out in the Glossary below).
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
6. 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, agents, contractors 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.
7. DATA RETENTION
How long will you use my personal data for?
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers (for tax purposes).
In some circumstances you can ask us to delete your data: see 'Request erasure' in the Glossary set out 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.
If you are entitled to lifetime access to any of our products or services, we may retain your personal data where that is necessary to give effect to that lifetime access.
8. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary set out below to find out more about these rights.
If you wish to exercise any of the rights set out in the Glossary, please contact us.
No fee usually 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 may refuse to comply with your request in such 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 may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. GLOSSARY
Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Third Parties
Internal Third Parties
Other companies in our group of companies (from time to time) (including those who may be acting as joint controllers or processors).
External Third Parties
• Service providers (such as those who provide IT, CRM, customer engagement platforms and system administration services).
• Professional advisers and assistance service providers (including lawyers, bankers, accountants, auditors, insurers and consultants).
• Payment processing service providers, such as Stripe and Paypal.
• HM Revenue & Customs, regulators and certain other public authorities.
• Certain other third parties, for example, market researchers, fraud prevention agencies, price comparison sites etc.
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 such 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 particular 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 to 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 which 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.