This policy is effective from 4 May 2021.
Our contact details:
Positive Momentum Limited registered in England under company number 4506172
Registered address: 2nd Floor, 168 Shoreditch High Street, London. E1 6RA
VAT number: 799 9836 20
Data Protection Officer: Rachel Stallion
Email address: firstname.lastname@example.org
Telephone number: +44 (0)1462 423375
Postal Address: Hyde Mill, Old Hale Way, Ickleford, Herts SG5 3UW
What we collect:
We may collect the following information from you:
- Name and company name
- Contact information including address, email address and telephone numbers
We may also collect additional personal data for the purpose of managing your business relationship with us. This information will be collected solely on the basis of you entering into a contract with us; or where the collection, processing and retention of that data is in our legitimate interests; or where you have agreed to the processing of your personal information.
How we get the personal information and why we have it:
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- You wish to learn more about Positive Momentum and what we do for our clients.
- Fulfil requests for participation in events or to send you key communications.
- Fulfilling contractual obligations.
We use the information that you have given us in order to share with you further information about Positive Momentum and the businesses authorised to trade under the Positive Momentum brand.
We will never sell, distribute or lease your personal information to any organisations outside of Positive Momentum Limited and the business authorised to trader under the Positive Momentum brand.
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
- Your consent. You are able to remove your consent at any time. You can do this by contacting – email@example.com
- We have a contractual obligation
- We have a legitimate interest
How we store your personal information:
We will only store your personal data in the UK. This means that it will be fully protected under the GDPR.
We will only transfer outside the UK with your express permission, and if you permit us to do so, you accept that some or all of your personal data may be transferred to countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
If the data provided by you is in response to an enquiry, we retain this data for administration purposes and contact purposes for a reasonable period, typically 12 months.
If it is part of a business relationship with us, we shall retain any personal data collected for the duration of the agreement and for a reasonable period thereafter, typically 6 years, for administrative purposes and contact purposes. We only retain personal information where there is a legitimate business reason for us doing so.
If you have registered for Positive Momentum Insights or you receive invitations to a survey, mailing campaign or events from Positive Momentum and you prefer not to receive future email communications from us, please write to firstname.lastname@example.org to unsubscribe from all Positive Momentum communications.
In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at email@example.com, Positive Momentum Limited, Hyde Mill, Old Hale Way, Ickleford, Herts SG5 3UW or +44 (0)1462 423375 if you wish to make a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at Positive Momentum Limited, Hyde Mill, Old Hale Way, Ickleford, Herts SG5 3UW.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
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