Privacy Policy 

Karen Williamson

Delivering Differently

karen@deliveringdifferently.co.uk

Welcome to the Delivering Differently privacy policy

Delivering Differently 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 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 Delivering Differently collects and processes your personal data through your use of our website and its services, including any data you may provide through our website when you request information and purchase our services.

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.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact me at karen@deliveringdifferently.co.uk

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

Our 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.

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 includes first name, last
    name, marital status, title, date of birth and gender.


  • Contact Data includes billing address,
    delivery address, email address and telephone numbers.


  • Financial Data includes bank account and
    payment card details.


  • Transaction Data includes details about
    payments to and from you and other details of services 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 our website.


  • Usage Data includes information about how
    you use our website, products and services.


  • Marketing and Communications Data includes
    your preferences in receiving marketing and information 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.

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 services;


    • purchase services on our website;


    • subscribe to our service or publications;


    • request marketing/information to be sent to
      you; 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. We may receive personal
    data about you from various third parties as set out below:


    • Technical Data from analytics providers such
      as Google based outside the EU.


      1. Contact, Financial and Transaction Data from
        providers of technical, payment and booking services such as Stay Lists Ltd
        trading as Inn Style based inside the EU.

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
    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 below.

Purpose/Activity: To register you as a new client

Type of data; 

(a) Identity

(b) Contact

Lawful basis for
processing including basis of legitimate interest

Performance of a contract with you

To process your order to provide the services including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(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 

(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 services)

To administer and protect our business and 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, 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) 

Marketing

We strive to provide you with choices regarding certain personal data uses,
particularly around communications and 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 messages at any time
by contacting us at any time.

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 may become inaccessible or
not function properly. 

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 or
permitted by law.

5. 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 party suppliers as instructed by you.


  • 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.

6. International
transfers

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

7. 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.

8. 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 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 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.

Details of retention periods for different aspects of your personal data
are available in our retention policy which you can request from us by
contacting us.

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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws
in relation to your personal data. Please click on the links below to find out
more about these rights:

If you wish to exercise any of the rights set out below, please contact
us.

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 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 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.

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.

Registered Office: Victoria House, Bondgate Within,

Alnwick, Northumberland NE66 1TA

Registered in England & Wales No: 12068096

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