PRIVACY POLICY

Last updated 9 November 2019

INTRODUCTION

Welcome to Startup-expert-plus.com (“website”), a website operated by Linda Hickman trading as Hickman & Associates (“Hickman & Associates”, “we”,”us”), a sole proprietorship.

Hickman & 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.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

Please also use the Glossary (end of the document) to understand the meaning of some of the terms used in this privacy policy.

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Hickman & Associates collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, take part in a competition, survey or sign up for an event(s).

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

Hickman & Associates is the controller and responsible for your personal data (collectively referred to as ”Hickman & Associates”, “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 INFORMATION

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

Hickman & Associates

Data Protection Officer

[email protected]

or write to us at

60 Gunters Mead

Copsem Lane KT109HJ, UK

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance 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. This version was last updated on 9 November 2019.

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 you visit.

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, maiden name, last name, username or similar identifier, title
      • Contact Data includes a postal address, email address, and telephone number.
      • Technical Data may include 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.
      • Profile Data may include your username and password, your interests, business sector, preferences, feedback and survey responses.
      • Usage Data include information about how you use our website, products, and services.
      • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

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 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.

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 and Contact Details 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 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[, server logs] and other similar technologies.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties [and public sources] as set out below
  • Technical Data from the following parties:

(a)  analytics providers such as Google based outside the EU;

(b)  advertising networks [such as [NAME] based [inside OR outside] the EU]; and

(c)  search information providers such as Google based inside OR outside the EU.

  • Identity and Contact Data from publicly available sources such as Companies House inside the EU

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 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 the basis of legitimate interest

 
To register you as a new customer

 

 (a) Identity

(b) Contact

 

 Performance of a contract with you

 
To process and deliver your order

 

 (a) Identity

(b) Contact

(c)Marketing and Communications

 

 (a) Performance of a contract with you

(b) Necessary for our legitimate interests

 
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

(d) Marketing and Communications

 

 (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 partake in a prize draw, competition or complete a survey

 

 (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

 (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 deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 

 (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

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

 
To use data analytics to improve our website, products/services, marketing, 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 and to inform our marketing strategy)

 
To make suggestions and recommendations to you about goods or services that may be of interest to you

 

 (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

 Necessary for our legitimate interests (to develop our products/services and grow our business)

 

 

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 and 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 third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time [by logging into the website 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, 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 this website may become inaccessible or not function properly.  Please review 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 that 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.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

      • 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 policy.

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.

 INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

[Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.]

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented]:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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.

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 fulfill the purposes we collected it for, including for 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 with 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 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 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.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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 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 overrides 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 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.

If you wish to exercise any of the rights set out above, 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 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 a number of requests. In this case, we will notify you and keep you updated.

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Our processing partners:

NEWSLETTER

If you sign up for our newsletter, we will send an e-mail to the registered e-mail address in which you will be asked to confirm your newsletter subscription (Double-Opt-In). This ensures that no third-party has misused your data. Under no circumstances will we sell your personal data for advertising or marketing purposes to third-parties or otherwise make them available for such. We will only share your personal information with technical services that are needed to deliver your newsletter. As a matter of course, you are free to unsubscribe to our newsletter service whenever you want by clicking on the unsubscribe button in the newsletter or sending an e-mail to [email protected].

As part of the registration of our newsletter, MailChimp collects your e-mail address and any other optional data. We use this information solely to send you the newsletter. You can unsubscribe at any time via the link provided at the bottom of each newsletter or notice to us. Your personal data is never made available to third parties (e.g. for marketing purposes) without your explicit prior consent and you can revoke your consent at any time.

ANALYTIC TOOLS

Personal data is only collected if you provide this on its own (for example when registering for our newsletter). Furthermore, no personal data is collected without your express consent.

As part of the registration of our newsletter, MailChimp collects your e-mail address and any other optional data. We use this information solely to send you the newsletter. You can unsubscribe at any time via the link provided at the bottom of each newsletter or notice to us. Your personal data is never made available to third parties (e.g. for marketing purposes) without your explicit prior consent and you can revoke your consent at any time.

We point out the data communication over the internet (e.g. via email) may pose a chance of security breach. Complete security of your personal data from the access of third parties is therefore not possible.

USE OF GOOGLE ANALYTICS

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, text files that are stored on your computer and allow an analysis of the use of the website. The information generated by the cookie about your use of this site are usually sent to a server of Google in the US and stored there.

In the case of activation of the IP anonymization on this Web site, the IP address of Google will be truncated within Member States of the European Union or other parties to the Agreement on the European Economic Area before. Only in exceptional cases, the full IP address is sent to a Google server in the USA and is shortened. On behalf of the operator of this site, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other website and internet related services to the site operator. Which is within the scope of Google Analytics that your browser sends IP address cannot be merged with other data held by Google.

You can prevent the storage of cookies by selecting the appropriate settings on your browser, we point out, however, that in this case, not all the features of this site are in full use. You can also extend the coverage of the generated by the cookie and prevent your use of the site-related data (including your IP address) to Google and the processing of these data by Google, by following the link below the available browser plug-in Download and install. Given the debate about the use of analytical tools with full IP addresses, we would like to point out that this website uses Google Analytics with the “_anonymizeIp ()” is used and therefore IP addresses are processed only shortened to reduce the anonymity.

GOOGLE ADWORDS TRACKING

This website uses Google AdWords conversion tracking, a web analytics service provided by Google Inc. (“Google”). Google AdWords Conversion Tracking also uses “cookies” that are stored on your computer and allow an analysis of the use of the Website by you. The information generated by the cookie about your use of this website to a Google server in the U.S. and stored there. Google will use this information to evaluate your use of the website, compiling reports on website activity for website operators and providing other website activity and internet related services.

In addition, Google may also transfer this information to third parties, unless required by law or if third parties process the information on behalf of Google. Google will not associate the data with other data held by Google. You can prevent the use of cookies in general if you prohibit in your browser to receive cookies.

FACEBOOK LIKE BUTTON

The website uses social plugins Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (hereinafter “Facebook”). When you visit pages on www.dataconomy.com that include such a plugin that automatically transmits data about your visitors’ behavior on the server from Facebook. The Dataconomy Media GmbH has no influence on the nature and extent of data collected and communicated to Facebook data. If you are logged into Facebook, Facebook can assign to visit your Facebook account. For more information about privacy on Facebook, visit http://www.facebook.com/policy.php . We, as the provider of the websites, have received no knowledge of neither the content nor the use thereof through Facebook.

TWITTER

Our pages include the functionality of Twitter. These services are offered by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA. Through the usage of Twitter and its “re-tweet” function, those websites will be linked to your Twitter account and shared with other users. This also entails forwarding data to Twitter.

We point out that we, as the provider of the sites, have neither any knowledge of the content of any data forwarded to Twitter nor Twitter’s usage thereof. Further details in this regard can be found in Twitter’s privacy policy: http://twitter.com/privacy.

You can modify your Twitter privacy settings within your account settings here:
http://twitter.com/account/settings

SSL TECHNOLOGY

We use a secure SSL (Secure Socket Layer) connection to protect the transmission of your data. This ensures that your personal data, including credit card details and contact information, is securely transmitted via the internet. The data is encrypted in such a way that it can only be read by our payment system. From a symbol (sealed padlock) in your browser’s window bar, you will recognize that you are now in the secured area. If your PC cannot process SSL – which may happen in rare cases – you do not need to worry that your data will be transmitted without secure encryption. In such cases, you will usually receive an error page drawing your attention to the problem. Then, you should best of all contact your provider.

We only work with Processing partners who are able to ensure an adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.