I care deeply about privacy and data protection and am committed to protecting your personal data.
This Privacy Notice (‘Notice’) seeks to provide an easy and comprehensible way to help you understand who I am, what personal data I collect about you, why I collect it, and what I do with it. Please keep in mind that personal data (also referred to as ‘data’ or ‘your data’) means any information or set of information from which I am able, directly or indirectly, to personally identify you, in particular by reference to an identifier, e.g., name, email address, telephone number, etc.
I strongly encourage you to take the time to read this Notice. If you do not wish for me to collect or use your data in accordance with this Notice, please do not provide it to me.
In this Notice, ‘Mitchell Willocks’, ‘I’, ‘me’, and ‘my’ means Mitchell Willocks and my associated entities.
1 When does this Notice apply?
This Notice addresses how I collect and use your data. Situations in which I will collect and use your data where this Notice will apply include:
- when you use my web properties, such as my websites, applications, and social media channels;
- when you interact with me via advertising and content on third-party websites;
- when you subscribe to communications from me, such as my newsletters;
- when you contact me, such as when you reach out to my support team;
- when you attend my events;
- when you provide to me your goods or services; and
- when you otherwise interact with me in your capacity as consumer, business customer, partner, supplier, contractor, or other person with a business relationship with me.
2 What categories of data do I collect?
Depending on how you interact with me, I may collect and use different data about you. Below is an overview of the categories of data I collect.
2a Information you provide to me directly
| Categories of data | Examples of types of data |
|---|---|
| Personal identification data | Full name and, if necessary, identity verification documentation (e.g., government-issued identification) |
| Demographic data | Age, gender identity, and location |
| Contact information data | Email address, telephone number, and address |
| Financial data | Payment information (e.g., card or bank account details, account holder name, and billing address) |
| Any other information that you decide to voluntarily share with me | Feedback, opinions, reviews, comments, uploaded files, interests, information provided for my due diligence process |
2b Information I collect automatically
| Categories of data | Examples of types of data |
|---|---|
| Device information | Hardware model, IMEI number and other unique device identifiers, MAC address, IP address, operating system version, and settings of the device you use to access my web properties |
| Log information | Time and duration of your use of my web properties |
| Location information | Your actual location (derived from your IP address or other location-based technologies), that may be collected when you choose to enable location-based features |
| Other information about your use of my web properties | Apps you use or websites you visit which direct to or are accessed from my web properties, and links you select in communications from me |
2c Information I may collect from other sources
To the extent permitted by applicable law, in addition to my web properties, I may also obtain information about you from other sources, such as via publicly available databases, my marketing and other business partners, social media platforms, and other third parties. For example, if you choose to link your social media account to your Mitchell Willocks account, certain data from your social media account may be shared with me.
3 Do I collect data from children?
(1) I do not intentionally collect data from children under the age of 16. If you are under the age of 16, you must not provide me with your data.
(2) I will collect data from children who are 16 or older but under the age of 18 in accordance with my Terms of Use.
4 How do I use your data?
(1) I may use your data for different legitimate reasons and business purposes. Below is an overview of the purposes for which I may process your data.
| Purposes | Examples |
|---|---|
| Conclusion and execution of agreements | Registration of users to my web properties to enable users to access and use my web properties, sales and billing, service communications, and account management |
| Providing support (upon your request) | Providing support via my support team to assist consumers and business customers to use my web properties and to resolve any disputes that may arise |
| Direct marketing | Promoting contact with consumers and business customers, email marketing, market surveys, and personalising your experience by presenting offers tailored to you (such as on my sites, applications or in other communications) |
| Assessment and screening of current or prospective customers, suppliers and business partners | Conducting due diligence |
| Research and development | To continuously improve my web properties, and the services and communications I provide to enrich the experiences of consumers and business customers |
| Security and protection of my interests and assets | Deploying and maintaining technical and organisational security measures (i.e., to detect and prevent fraud, spam, abuse, security incidents, and other harmful activity), conducting internal audits and investigations, and conducting assessments to verify conflicts of interest |
| Compliance with legal obligations | Disclosing data to government institutions and supervisory authorities as applicable in all countries in which I operate, record-keeping and reporting obligations, conducting compliance audits, compliance with government inspections and other requests from government or other public authorities, responding to legal process, pursuing legal rights and remedies, and managing any internal complaints or claims |
| Defence of legal claims | Establishment, exercise or defence of legal claims to which I am or may be subject |
(2) You may choose to remain anonymous or use a pseudonym when interacting with me, unless the use of your true identity is a legal requirement or it is impracticable for me to deal with you on such basis. If I ask you to provide me with your data, but you choose not to, in some cases I will not be able to provide you with the full functionality of my web properties. I might also not be able to respond to requests you might have.
5 How do I use your data to market to you?
(1) I may send you promotional communications about my services, events, and promotions.
(2) Such promotional communications may be sent to you via different channels such as via email, phone, text message, postal mail, and third party social networks.
(3) To provide you with the best experience, these communications may be tailored to your preferences (e.g., as you indicate these to me or as I may have inferred from your interactions with me).
(4) When required by applicable law, I will seek your consent before sending marketing communications to you.
(5) I will also give you the opportunity to withdraw your consent at any time. In particular, you can always opt-out from receiving marketing communications via email by following the unsubscribe instructions provided in each email. If you have an account accessible via my web properties, you may be given the option to change your communication preferences under the relevant section of my web properties. You can always contact me to opt-out from receiving marketing communications.
(6) Please note that even if you opt-out from receiving marketing communications, you might still receive transactional and administrative communications from me, such as order confirmations, notifications about your account activities, and other important notices.
6 Do I use cookies or other similar tracking technologies?
(1) I may use cookies or other similar tracking technologies on my web properties.
(2) Cookies are small text files that are stored in your browser’s cache when you visit certain websites. I may also use similar tracking technologies, such as pixels and web beacons. For consistency’s sake, I refer to all these tracking technologies as ‘cookies’.
(3) Cookies may be used for many different purposes. For example, cookies can be used to show that you have visited my web properties before and to identify which parts of my web properties you might be most interested in. Cookies can also improve your online experience by storing your preferences during your visit to my web properties.
(4) In order to manage your cookie preferences, you may alter your your browser’s preferences at any time. You may accept all, or certain, cookies. If you do reject my cookies in your browser’s preferences, you may find that certain sections of my web properties will not work.
(5) I will handle any data collected by cookies in the same way that I handle all other data under this Notice.
(6) You can find out more about my use of cookies in my Cookies Notice.
7 On what legal basis do I use your data?
To be able to process your data, I may rely on different legal bases, including:
- your consent (only when legally required or permitted). If I rely on your consent as a legal basis for processing your data, you may withdraw your consent at any time;
- the necessity to establish a contractual relationship with you and to perform my obligations under a contract;
- the necessity for me to comply with legal obligations and to establish, exercise, or defend against legal claims;
- the necessity to pursue my legitimate interests, including:
- to ensure that my networks and information are secure;
- to enable me to administer and generally conduct business;
- to prevent or investigate suspected or actual violations of law, breaches of contract, or non-compliance with my policies;
- the necessity to respond to your requests;
- the necessity to protect the vital interests of any person; and
- any other legal basis permitted by applicable law.
8 Under what circumstances do I share your data?
(1) I will not share any of your data except in the limited cases described in this Notice.
(2) If it is necessary for the fulfilment of the purposes described in this Notice, I may disclose your data to the following entities:
- Service providers: like many businesses, I may outsource certain data processing activities to trusted third party service providers to perform functions and provide services to me, such as ICT service providers, consulting providers, and marketing and communications providers;
- Business partners: I may share your data with trusted business partners so they can provide you with the services you request;
- Public authorities: when required by law, or as necessary to protect my rights, I may share your data with entities that regulate or have jurisdiction over me;
- Professional advisors: I may share your data with other parties including professional advisors, such as banks, insurance companies, auditors, lawyers, accountants, other professional ad- visors;
- Other parties in connection with corporate transactions: I may also, from time to time, share your data in the course of corporate transactions, such as during a sale of a business or a part of a business to another company, or any reorganisation, merger, joint venture, or other disposition of my business, assets, or stock (including in connection with any bankruptcy or similar proceeding).
9 Under what circumstances do I transfer your data abroad?
(1) Due to the global nature of my activities, data you provide to me may be transferred to or accessed by trusted third parties from many countries around the world. As a result, your data may be processed outside the country where you live, if this is necessary for the fulfilment of the purposes described in this Notice.
(2) If you are located in the European Economic Area (‘EEA’), I may transfer your data to countries located outside of the EEA. Some of these countries are recognised by the European Commission as providing an adequate level of protection.
(3) With regard to transfers from the EEA to other countries that are not recognised by the European Commission as providing an adequate level of protection, I will take reasonable steps to protect your data, such as by incorporating a requirement to comply with this Notice as part of my contracts with trusted third parties.
10 How long will I retain your data?
I keep your data for as long as necessary to fulfil the purposes for which it has been collected. Please keep in mind that in certain cases a longer retention period may be required or permitted by law. The criteria used to determine my retention periods include:
- How long is the data needed to provide you with my services or to operate my business?
- Do you have an account with me? In this case, I will keep your data while your account is active or for as long as needed to provide the services to you.
- Am I subject to a legal, contractual, or similar obligation to retain your data? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation.
11 How do I protect your data?
To protect your data, I will take appropriate measures that are consistent with applicable data protection and data security laws and regulations, including requiring my service providers to use appropriate measures to protect the confidentiality and security of your data. Depending on the state of the art, the costs of the implementation, and the nature of the data to be protected, I put in place technical and organisational measures to prevent risks such as destruction, loss, alteration, unauthorised disclosure of, or access to your data.
12 What do you need to do when providing your data to me?
It is important to keep in mind that it is your responsibility to ensure, to the best of your knowledge, that the data you provide me with, are accurate, complete and up-to-date. Furthermore, if you share with me data of other people, it is your responsibility to collect such data in compliance with local legal requirements. For instance, you should inform such other people, whose data you provide to me, about the content of this Notice and obtain their consent.
13 What choices are available to you?
(1) I aim to provide you with access to your data. Generally, you can autonomously control the data I hold about you (e.g., by logging in to your account) to update, modify or, when possible, delete it.
(2) You can also contact me in relation to your privacy and the protection of the personal data which I hold about you if you would like to:
- review, change, or delete the data you have supplied me with and I hold about you (to the extent I am not otherwise permitted or required to keep such data);
- restrict my ability to undertake certain data processing activities (e.g., opt-out from marketing communications);
- receive a copy of your data (in a common machine-readable format, to the extent it is required by applicable law);
- withdraw your consent to the use of your data where consent was previously provided as the legal basis for such use (to the extent I am not otherwise permitted to continue such use); and
- ask me any other questions related to the protection of your data.
(3) You can contact me in relation to your privacy and the protection of the personal data which I hold about you by completing my Data Subject Request form.
(4) I will do my best to address your request within a reasonable amount of time and free of charge. I may ask you to verify your identity before I can act on your request. I may decline your request in certain circumstances, to the extent permitted by applicable law. If I do refuse your request, I will notify you of my reasons.
(5) If you are unsatisfied with my response, or if you consider that I have collected or used your data in breach of applicable law, you may choose to make a complaint to the relevant data protection authority in your jurisdiction.
14 Changes to this Privacy Notice
(1) I may update or modify this Notice from time to time in response to changing legal, technical, or business developments. I will obtain your consent to any material Notice changes if and where this is required by applicable law. The date of the most recent version of this Notice will appear at the bottom of this page.
(2) When I update this Notice, I will take appropriate measures to inform you, consistent with the significance of the changes I make. For example, I will notify you of any changes to this Notice by posting a new Notice and updating the ‘last updated’ date at the bottom of this page or by sending the new Notice to you via email, where appropriate.
Last updated on 22 March 2020.