To be very clear on this We will
- Always keep your data safe and private.
- Never sell your data or share it without your explicit permission
- Allow you to manage and change your marketing choices at any time.
- Allow you to exercise your Rights
1. Definitions and Interpretation In this Policy, the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13 & 14, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003; “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our” means AmberLife UK Ltd, a limited company registered in England under company number 06749093 whose registered address is Maidment Pinkus & Partners, 7 Cambridge Court, 3 Holborn Close, Mill Hill, London, NW7 4AZ.
2. Information About Us
Our Site is owned and operated by AmberLife UK, a limited company registered in England under company number 06749093 whose registered address is Maidment Pinkus & Partners, 7 Cambridge Court, 3 Holborn Close, Mill Hill, London, NW7 Our Data Protection Officer is Mark James and can be contacted by email at email@example.com or by Telephone at + 44(0) 7973 318137
3. What Does This Policy Cover?
4. Your Rights
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
• The right to be informed about Our collection and use of personal data;
• The right of access to the personal data We hold about you (see section 12);
• The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 15);
• The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 15);
• The right to restrict (i.e. prevent) the processing of your personal data;
• The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
• The right to object to Us using your personal data for particular purposes; and
• Rights with respect to automated decision making and profiling. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 15 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. https://ico.org.uk For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
Name and email addresses; as provided by You when you Subscribe to our weekly newsletter-“Make Your Monday’s Matter” and other AmberLife specific emails we may send from time to time, or when you use any of the contact forms on Our Site.
And collected when you visit Our Site:
• Your IP address;
• Your web browser type and version;
• Your operating system;
• And a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
6. How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
Our use of your personal data will always have a lawful basis to be held by Us, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
• Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
• Replying to emails from you;
• Supplying you with emails that you have opted into – you may unsubscribe or opt-out at any time by selecting “Unsusbcribe” on any email you receive from Us;
• Analysing your use of Our Site to enable Us to continually improve Our Site and your user experience. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Third parties who link to our Our Site may use third-party Cookies, as detailed below in section 13 & 14. Please refer to section 13 & 14 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties before accepting their cookies.
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
• Name & Email address is kept for 7 years, purely to maintain contact with you and where you have opted in to do so, receive Our marketing emails.
• IP Address, referring URL, Web browser type and Operating system is kept for 26 months and then deleted.
• Referring Facebook adverts using pixel based tracking to know which ad directed you to Our Site.
7. How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site. Steps We take to secure and protect your data include:
• Remote Secure Storage with Encryption at REST
• TLS for sending and receiving Emails
• Addition Information Security Measures as applicable to the Risks and Impact associated with the data held. If you would like to know more about our additional Information Security Procedures or our company wide Data Protection Policies, please contact firstname.lastname@example.org
8. Do We Share Your Data?
We never sell or Share your Personal Data without your consent or other Lawful reasons. If you object to Us Processing Your Personal Data in any way you can tell us to stop, citing why you object
We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR including:
• ConstantContact LLC. A Company operating under EU-US Privacy Shield; Privacy Shield List
• Eventbrite Services. A Company operating under EU-US Privacy Shield; EU-US Privacy Shield Notice
• Google. A GDPR Compliant company. https://policies.google.com/privacy/update
• Facebook Inc. A Company operating under EU-US Privacy Shield; EU-US Privacy Shield Notice https://www.facebook.com/business/gdpr
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority such as HMRC for example.
9. What Happens If Our Business Changes Hands?
In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
When you submit personal data via Our Site, We aim to give you strong controls on Our use of your data for direct marketing purposes including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails or at the point of providing your details.
11. Your Right to Withhold Information
You may access Our Site without providing any data at all. Or if you prefer can disable all Cookies via your chosen Browser, however doing so may prevent you ability to access other websites that you use and may need such information to provide their services.
12. How Can You Access Your Data? You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR and this is called a Data Subject Access Request. No fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com or using the contact details below in section 15.
By using Our Site you may receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for basic Website Analytics. For more details, please refer to section 7, above, and to section 13 & 14 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
You may, if you wish, deny consent to the placing of Cookies; this will not affect your use of or ability to move around Our Site.
Our Site uses Website analytics services provided by Google Analytics.
Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, however, whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This anonymous data is sometimes shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
The analytics services used by Our Site use the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|Google Analytics||Third Party||Google To Collate basic information about which website you visited Us from, how long you stay and what you interact with on Our Site|
|Facebook Pixel||Third Party||Help Track Conversions from Facebook Ads and basic analytics.|
|Eventbrite||Third Party||Eventbrite||To allow you to purchase tickets to AmberLife events and basic analytics.|
|Sumo||Third Party||Sumo||To allow you to ask questions through Our Site|
To manually manage your cookie preferences per browser type and to have the option to block any non-essential cookies please see below for instructions based on the browser used.
Microsoft Internet Explorer versions 7.0, 8.0, 9.0, 10.0
• Click on “Tools” at the top of your browser window (use the cog icon in IE 9.0 & 10.0) and select “Internet options”.
• Click on the “Privacy” tab
• Under the Settings section check the level is set to Medium or below, which will enable cookies in your browser.
• Settings above Medium will disable cookies and could cause the site to function not as we would expect.
• Click on the spanner icon found at the top of the browser screen.
• Now choose “Settings”.
• If not already chosen click on the “+Show advanced settings” link at the bottom.
• Just under the Privacy section click on the “Content settings…” button.
• You now have a choice to either disable all cookies by ticking “Block sites from setting any data” or disable only 3rd party cookies by ticking? Block third-party cookies and site data?.
• Click on OK to save the changes.
• Click on “Tools” at the top of your browser window and select “Options”.
• In the popup window select the “Privacy” option.
• Now under the History section click the drop down box alongside “Firefox will:” and then choose “Use custom settings for history”.
• You now have a choice to either disable all cookies by unticking “Accept cookies from sites” or disable only 3rd party cookies by unticking “Accept third-party cookies”.
• Click on OK to save the changes.
• Click on the Cog icon at the top of your browser window and select the “Preferences”.
• Click on “Security”, then check the option that says “Block third-party and advertising cookies”.
• Click “Save”.
To block cookies on a mobile or other devices please consult your device settings and documentation.
14. Disabling Cookies
You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time and this will not impact your use of Our Site.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. Contacting Us