Effective Date: 15th March 2018
Last Updated: 25th April 2018
This privacy notice provides you with details of how we collect and process your personal data through your use of our site fast-pathways.com and our landing pages resolve-stress.com, including any information you may provide when you purchase a product or service, sign up to our regular emails, or take part in a prize draw or competition. By providing us with your data, you warrant to us that you are over 13 years of age.
We are committed to ensuring that your privacy is protected. Information which you provide to us will be used only in accordance with this privacy statement. We do update this Policy, so please review regularly. You should check this page from time to time to ensure that you are happy with any changes.
Sue Evans, as the Data Controller for Fast and Lasting Change Ltd, is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full Contact Details: Fast and Lasting Change Ltd
Email address: email@example.com
Postal address: 23 Reedville, Prenton, Wirral CH43 4UH
It’s very important that the information we hold about you is accurate and up to date. If at any time your personal information changes, please let us know by emailing firstname.lastname@example.org, or by using the links in our email footer to update your details in our preference centre.
The Data We Collect About You
Personal data means any information capable of identifying an individual. It doesn’t include aggregated or anonymised data which can’t be traced back to an individual. Personal data we may process about you includes
- Identity Data may include your first name, last name, title, date of birth and gender.
- Contact Data may include your address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may includeyour username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving our marketing communications, and your communication preferences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered - but if we do, we will notify you at the time.
How We Collect Your Personal Data
We collect data about you through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you order our products or services, subscribe to our service or publications, request resources or marketing be sent to you, enter a competition, promotion or survey, or give us feedback.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources such as analytics providers such as Google based outside the EU.
- A cookie is a small file which asks permission to be placed on your computer's hard drive. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
- Cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you don’t. A cookie in no way gives us access to your computer or any information about you.
- We use traffic log cookies to identify which pages are being used. This helps us improve our website by tailoring it to customer needs. We use this information only for analysis purposes, and then the data is removed from the system
- You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
How We Use Your Personal Data
We will use your personal data only when legally permitted. The most common uses of your personal data are to perform the contract between us or to send you information or resources which you’ve requested; 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; or where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing email@example.com, or by updating your subscriber preferences, accessed from the link in our email Footers.
Purposes for processing your personal data
Under Article 6 of the European GDPR (General Data Processing Regulation) legislation, we are obliged to make you aware of the Lawful basis under which we process your personal data. We may process your personal data on more than one lawful ground, depending on the specific purpose for which we’re using your data. If you need details of the lawful basis for our processing of your data, please email firstname.lastname@example.org. The bases under which we process personal data are
Basis a) Consent: By providing your personal details on a web or paper form, you give us permission to use that data for the stated purpose(s). e.g. by opting in to receive our communications
Basis b) Contract: The processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract. e.g. if you have purchased (or a third party such as your employer, has purchased for you) any of our products or services. Any data which you provide to us will not be shared with such third parties, except in anonymised or aggregated form, preventing it from being linked to you as an individual.
Basis f) Legitimate interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal data which overrides those legitimate interests) e.g. maintaining our internal records, or understanding your site usage to help us improve our services and user experience.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing. You can ask us to stop sending you marketing messages at any time by emailing email@example.com, or by using the Unsubscribe and preferences links in our email footers. Opting out of communications means that you’ll no longer receive communications from which you’ve unsubscribed, but doesn’t automatically mean that we’ll delete your personal data. If you require us to delete your data, please email firstname.lastname@example.org.
If you’re not happy with any aspect of how we collect and use your data, please in the first instance let us know so that we can try to resolve it for you. You have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
Disclosures of Your Personal Data
- We may have to share your personal data with the providers of IT and system administration services, or with third parties to whom we sell, transfer, or merge parts of our business or our assets. We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We allow such third parties to process your personal data only for specified purposes and in accordance with our instructions.
We use IT services provided by several organisations based outside the European Economic Area (EEA). Countries outside of the EEA don’t always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of data security by ensuring at least one of the following safeguards is implemented:
- We will transfer your personal data only to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- We may use specific service provider contracts, codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. Please email email@example.com you’d like further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 such data. They will process your personal data only 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.
We will retain your personal data only 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 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, for tax purposes, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers. In some circumstances you can ask us to delete your data.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to / correction of / transfer of / erasure of your personal data.
- Object to, or request restrictions on the processing of your personal data.
- Withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email firstname.lastname@example.org.
You won’t 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 these circumstances.
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. We try to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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 notice of every website you visit.