Policy key definitions:
- “I”, “our”, “us”, or “we” refer to the business, [Business name & other trading names].
- “you”, “the user” refer to the person(s) using this website.
- GDPR means General Data Protection Act.
- PECR means Privacy & Electronic Communications Regulation.
- ICO means Information Commissioner’s Office.
- Cookies mean small files stored on a users computer or device.
Processing of your personal data
Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.
Lawful basis: Consent
Data retention period: We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.
Sharing your information: We do not share your information with third parties.
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
Your individual rights
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
Some cookies are required to enjoy and use the full functionality of this website.
Cookies that we use are;
- Google Analytics: To understand the traffic and activity on our website
- Hubspot: To understand traffic and activity on our website and to identify which users are visiting which pages
- Linkedin: To be able to identify who has visited our website in order to serve them adverts about our services
- Google Adwords: To be able to identify who has visited our website in order to serve them adverts about our services
Data security and protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Transparent Privacy Explanations
We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.
Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an EMS (email marketing service) provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. There is an ‘unsubscribe’ and ‘manage preferences’ link in any marketing messages we send you.
Our EMS provider is Hubspot. We hold the following information about you within our EMS system;
- Email address
- I.P. address
- Subscription time & date
Security incident response
Freedman International’s security incident process flows and investigation data sources are pre-defined during recurring preparation activities and exercises and are refined through investigation follow-ups. We use standard incident response process structures to ensure that the right steps are taken at the right time.