Privacy Policy

1. Introduction

I respect your privacy and am committed to protecting your personal data. This privacy policy will inform you about how I look after your personal data when you visit my website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy aims to give you information on how I collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up for my newsletter, create an account, or purchase a product or service.

This website is not intended for children and I do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data.

2. Controller

Simon Jacobs is the controller and responsible for your personal data (collectively referred to as "I", "me", or "my" in this privacy policy).

I have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details
Full name of legal entity: Simon Jacobs
Email address: simon@jacobsandco.com
Postal address: [Your Address]
Telephone number: +1 (555) 123-4567

You have the right to make a complaint at any time to the supervisory authority for data protection issues in your jurisdiction. In the EU, this would be the data protection authority of the EU country in which you reside or work. In the UK, this is the Information Commissioner's Office (ICO, www.ico.org.uk). In the US, this varies by state. I would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact me in the first instance.

3. The Data I Collect About 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).

I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details (though I do not store complete payment information, as this is processed by third-party payment processors).
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from me.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use my website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from me and my third parties and your communication preferences.

I also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this privacy policy.

I do not collect any Special Categories of Personal Data about you (this 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). Nor do I collect any information about criminal convictions and offenses.

4. How Is Your Personal Data Collected?

I use different methods to collect data from and about you including through:

• Direct interactions. You may give me your Identity, Contact and Financial Data by filling in forms or by corresponding with me by post, phone, email or otherwise. This includes personal data you provide when you:
  • create an account on my website;
  • subscribe to my publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give me feedback or contact me.
• Automated technologies or interactions. As you interact with my website, I will automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies, server logs and other similar technologies. I may also receive Technical Data about you if you visit other websites employing my cookies.
• Third parties or publicly available sources. I will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    • analytics providers such as Google;
    • advertising networks; and
    • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.

5. How I Use Your Personal Data

I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:

• Where I need to perform the contract I am about to enter into or have entered into with you.
• Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where I need to comply with a legal obligation.

Generally, I do not rely on consent as a legal basis for processing your personal data although I will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting me.

Purposes for which I will use your personal data

I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.

Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I am using your data. Please contact me if you need details about the specific legal ground I am relying on to process your personal data where more than one ground has been set out in the table below.

6. Disclosures of Your Personal Data

I may share your personal data with the parties set out below for the purposes set out in the table above.

• Internal Third Parties such as other companies or individuals who work for me and provide services to me.
• External Third Parties such as:
  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Tax authorities, regulators and other authorities who require reporting of processing activities in certain circumstances.
• Third parties to whom I may choose to sell, transfer or merge parts of my business or my assets. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy policy.

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my third-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 my instructions.

7. International Transfers

I share your personal data within my organization and with external third parties, which may involve transferring your data outside the European Economic Area (EEA).

Whenever I transfer your personal data out of the EEA, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• I will only 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 I use certain service providers, I may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where I use providers based in the US, I may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact me if you want further information on the specific mechanism used by me when transferring your personal data out of the EEA.

8. Data Security

I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.

I 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 I am legally required to do so.

9. Data Retention

I will only retain your personal data for as long as reasonably necessary to fulfill the purposes I collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. I may retain your personal data for a longer period in the event of a complaint or if I reasonably believe there is a prospect of litigation in respect to my relationship with you.

To determine the appropriate retention period for personal data, I consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law I have to keep basic information about my customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask me to delete your data: see your legal rights below for further information.

In some circumstances I will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case I may use this information indefinitely without further notice to you.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.
• Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.
• Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios:
  • If you want me to establish the data's accuracy.
  • Where my use of the data is unlawful but you do not want me to erase it.
  • Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you.
• Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact me.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I could refuse to comply with your request in these circumstances.

What I may need from you

I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.

Time limit to respond

I try to respond to all legitimate requests within one month. Occasionally it could take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

11. Cookies

My website uses cookies to distinguish you from other users of my website. This helps me to provide you with a good experience when you browse my website and also allows me to improve my site.

A cookie is a small file of letters and numbers that I store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

I use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of my website. They include, for example, cookies that enable you to log into secure areas of my website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow me to recognize and count the number of visitors and to see how visitors move around my website when they are using it. This helps me to improve the way my website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognize you when you return to my website. This enables me to personalize my content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to my website, the pages you have visited and the links you have followed. I will use this information to make my website and the advertising displayed on it more relevant to your interests. I may also share this information with third parties for this purpose.

You can find more information about the individual cookies I use and the purposes for which I use them in the table below:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which I have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of my site.

12. Changes to the Privacy Policy

I reserve the right to update this privacy policy at any time, and I will provide you with a new privacy policy when I make any substantial updates. I may also notify you in other ways from time to time about the processing of your personal information.

13. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to simon@jacobsandco.com.