Cocktail Credentials (“CC”) is committed to preserving the privacy of all its customers. This Privacy Notice will inform you about how, as a group, we collect, process and protect your personal data whether provided through this website (cocktailcredentials.com), via our other websites and companies in the group (altyerre.com) or via other means e.g. an email address obtained from an event or training course. References in this notice to Cocktail Credentials shall also cover Altyerre Ltd.
WHO WE ARE:
Altyerre Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full contact details are:
Full name of legal entity: Altyerre Limited
Email address: firstname.lastname@example.org
Postal address: 4 First Avenue London SW14 8SR
Telephone number: 020 8876 699
It is important that the personal data we hold about you is accurate and current. Please kindly let us know if your personal data changes during your relationship with us by emailing us at email@example.com
INFORMATION THAT WE COLLECT FROM 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. The most common types of personal data we are likely to process are as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, business name
- Contact Data includes billing address, delivery address, email address and telephone numbers
- Financial Data includes bank account details
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us
- Technical Data includes your browser type and version, and your operating system and platform. We do not collect any Technical Data which enables us to personally identify the users of our website
- Profile Data includes your username and password, preferences, feedback and survey responses
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences
- Any other information as provided during a telephone briefing, online contact form or email correspondence
- Photographs including those taken of attendees at events
- CV & application forms as submitted by you personally
We only collect information that we need to carry out our business. What information we collect will depend on our relationship with you.
We will collect information about you in order to provide our services, including your contact information such as your address, title, email address and telephone number, your bank account details (if needed for administration of our account with you) and other miscellaneous documents relevant to the work we carry out for you. This will include information that we might obtain about you if you work for one of our clients.
We will collect contact information in order to enable us to manage our relationship with you, and bank account details (to enable payment for services). In the course of providing services to us we may collect other information from you which is relevant the provision of those services. If we engage you to provide services on behalf of our clients we may collect and use additional information that we need in order to engage you and to comply with our obligations to our clients, for example your description or photograph, your interests and background, your age. If we have to arrange travel for you we may need to obtain your passport details and information related to your health (for insurance purposes).
We may collect information about you that you provide to us or that we obtain through our own research so that we may contact you and so that we are able to see what services you might be interested in and how we might best provide them to you or your company. This may include your work experience and professional background, your interests and your contact information.
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
HOW DO WE COLLECT YOUR DATA
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 products or services
- request information to be sent to you
- register for our newsletter or complete a form on our website or respond to a survey; or
- give us some feedback
- Third parties e.g. our clients, suppliers or other direct contacts
HOW WE USE YOUR PERSONAL DATA
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 3rd party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal or regulatory obligation
Therefore our lawful grounds for processing your data are based on legitimate interests, legal obligation and contractual requirements.
Purpose: To register you as a new client or to make suggestions to you that we believe may be of interest
- a) Fulfilment of a contract
- b) Necessary for our legitimate interests (e.g. so that we can provide you with information about events we are running and misc. products and/or information which we think may be of interest or relevant to you and to grow your and our business)
Purpose: Prospect Data provided through online enquiry/other route
- a) Fulfilment of a contract (e.g. so that we can respond to an enquiry, follow-up a lead prior to entering into a contract)
- b) Necessary for our legitimate interests (e.g. to reply to your communications and keep records for our business)
Purpose: To process and deliver services or to pay for services we use
- Fulfilment of a contract with you
- Necessary for our legitimate interests (e.g. to pay for products purchased on your behalf, to recover debts due to us)
Purpose: To manage our relationship with you e.g. asking you to complete a client satisfaction survey, notifying you about changes to our terms/ registered office address etc, providing you with information about our business which we think may be relevant to you)
- Fulfilment of a contract with you
- Necessary to comply with a legal obligation
- Necessary for our legitimate interests (e.g. to see which products are of interest to our customers, to develop our products and to grow our business)
Purpose: To administer, manage and protect our business and website e.g. through user data (cookies) and technical data (how you use our website incl. IP address, login, browser details, length of visit etc) which allows data analysis, testing, system maintenance & security, reporting and hosting of data etc)
- Legitimate interests (in properly administering and running our website and business)
- Legal obligation
Purpose: To deliver relevant information and content to you and to evaluate the effectiveness of that content:
- Legitimate interests in delivering against client objectives and in developing growing our business
Purpose: Keeping records
- Compliance with legal obligation
- Legitimate interests (responsible business administration or defending, pursuing or establishing a legal claim)
Purpose: in order to obtain professional advice and insurance
- Legitimate interests to grow and protect our business
For more information on this please email us at firstname.lastname@example.org.
We will never share your personal data with 3rd Parties for marketing purposes without your express opt-in consent.
You can ask us to stop sending you marketing messages at any time by either clicking the unsubscribe link found at the bottom of any email we send or emailing us at email@example.com
Where you opt out of receiving marketing messages, this will not apply to personal data provided to us where it relates to a transaction or a contract.
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 at firstname.lastname@example.org.
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.
HOW WE COLLECT YOUR PERSONAL DATA
DISCLOSURE OF YOUR INFORMATION
We may have to share your information with 3rd Parties as set out above ‘How we use your personal data’.
3rd Parties include
- Service providers who assist us in our business and the projects we deliver for our clients
- Professional advisers including lawyers, bankers, auditors, accountants and insurers based in the EU or the USA
- Government Bodies who require us to report processing activities or disclose your personal data in certain circumstances
- 3rd Parties to whom we sell, transfer or merge parts of our business or assets
We require all 3rd Parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our 3rd-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.
Where you are one of our clients or have otherwise agreed to be contacted for marketing we may use your personal information to send you information about us and our services. You can unsubscribe from receiving them at any time, details of how to unsubscribe will be included at the bottom on each electronic mailing we send you. You also have the option of “unsubscribing” from our mailing list at any time thereby disabling any further e-mail or other communication from being sent to you by emailing email@example.com
We will action any opt out request from you without delay.
LINKS TO OTHER SITES
Your personal information may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) and may also be processed by staff operating outside the EEA who work for us, or for one of our 3rd Party service providers.
When we, or our permitted 3rd parties, transfer your information outside the EEA we will take all reasonable steps to ensure that such transfer is subject to appropriate safeguards, including entering into agreements with the party to whom we transfer such information in accordance with EC approved model data transfer agreements.
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
- Where we use US-based providers 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.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe
If none of the above are available, we may request your explicit consent to transfer the data – you can withdraw your consent at any time.
We have put in place security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or shared. In addition, we limit access to your personal data to those employees and partners who have a business need to know. They will only process your personal data on our instructions and they are bound by confidentiality.
We have procedures in place 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 only keep the information we collect about you for as long as required for the purposes we collected it for and/or for the purposes of satisfying any legal, accounting, or reporting requirements. This will involve us periodically reviewing our files to check that information is accurate, up-to-date and still required.
When deciding what is the correct time to keep the data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means and legal requirements.
Where we are permitted to send you direct marketing communications we may retain your contact information necessary for this purpose, for as long as you do not unsubscribe from receiving the same from us. If you opt out from marketing, we will retain your information to enable us to respect your wishes to not be contacted for marketing purposes.
By law, for tax purposes, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers.
In some circumstances we may anonymise your personal data 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 in relation to your personal data under data protection laws to request access, correction, erasure, to object to processing, restriction, a transfer of your data and, where the legal grounds for processing is consent, to withdraw consent.
If you wish to exercise any of the rights set out above, please email firstname.lastname@example.org.
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 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 than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.
If you are not happy with any of aspect of how we collect and use your personal data you have the right to complain to the Information Commissioners Office (ICO). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
All comments, queries and requests relating to our use of your information are welcomed and should be addressed to email@example.com.
What is a cookie?
A cookie is a small file of letters and numbers that we store on your browser or hard drive (of a computer or other device) if you agree. When you visit a website, a computer asks your computer for permission to store this file so that it can remember who you are.
What cookies do we use?
Cookies we use include ‘persistent cookies’ (the cookie is stored by the web browser until a set end date) and ‘per session’ cookies (the information expires at the end of the session when the website is closed). We also use ‘analytical cookies’. Analytical cookies allow us to recognise and count the number of visitors to the site and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. So, the information we gather through cookies may include, amongst other things, subscription data, the date and time of visits, the pages viewed and the time spent at our website and the information may be stored between visits. This information can also help us to understand how the website is used.
By continuing to use this Website, you are deemed to agree to the use of the cookies as described here. If you do not consent to the use of these cookies however then you can easily modify your web browser settings to block some or all cookies. Kindly note if you modify your browser settings to block all cookies (including essential cookies) some aspects of the Website may not work properly and you may not be able to access all areas of the Website. You can find out more about cookies and adjusting browser settings at www.allaboutcookies.org
To opt out of google analytics cookies visit https://tools.google.com/dlpage/gaoptout
Please note that the cookies used on the Website may change from time to time. You should check back regularly to see if we have made any changes to this Policy and the cookies referred to in it.
Please check back frequently to see any updates or changes to our policy.
Last updated May 2018