What we collect
We collect certain information or data about you when you use www.freespiritconsulting.com or contact us using the website forms.
- questions, queries or feedback you leave, including your email address, if you contact Free Spirit Consulting Ltd
- your email address and subscription preferences when you sign up to our email newsletters, and
- how you use our emails – for example whether you open them and which links you click on, your IP address, and details of which version of web browser you used as well as information on how you use the site, by using cookies and pre-tagging techniques.
This information helps us to:
- send you our newsletters from time to time if you have consented to this
- ensure that content from our site is presented in the most effective manner for you and for your device
- provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes
- carry out our obligations arising from any contracts entered into between you and us
- allow you to participate in interactive features of our service, when you choose to do so, and
- notify you about changes to our service.
This information can be viewed by authorised people in Free Spirit Consulting Ltd. to:
- improve the site by monitoring how you use it
- gather feedback to improve our services, for example our email newsletters
- respond to any feedback you send us.
When you sign up to our email newsletters
We use Constant Contact for our email newsletters.
Constant Contact has staff based outside the UK and EEA and stores your data in the USA. We will continue to send you email newsletters until you tell us not to or use the unsubscribe option on any of our emails.
How we may use your personal information
Direct Marketing: We may send postal marketing which further the aims and objectives of Free Spirit Consulting Ltd. We will also make sure our postal marketing is relevant for you, tailored to your interests.
Personalisation: Where the use of the information enables us to personalise, enhance or otherwise improve our services/communications for the benefit of our clients.
Analytics: To use your personal information for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalised or aggregated basis, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.
Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.
We will also hold information about you so that we can respect your preferences for being contacted by us.
Securing your information
We have put in place security measures to prevent your personal information from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We ensure that only those employees and partners, who need access to your personal information as part of their business role, are given access. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we need to.
Disclosing your information
There are a number of lawful bases which can be used to process your personal information. One of these is legitimate interest and means we can process your information where we have a genuine reason and it is not harming your rights.
What does this mean? When you provide your personal information, we may use it to provide information about what we do as an organisation. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights. Our legitimate business interests do not automatically override your interests – we will never use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Some examples of this lawful basis would be for direct marketing, maintaining the security of our system, data analytics, enhancing, modifying or improving our services, identifying usage trends and determining the effectiveness of our campaigns.
Remember, you can change the way you hear from us or withdraw your permission for us to process your personal details at any time by sending an email to firstname.lastname@example.org.
Retaining your information
We hold your information only as long as necessary for each reason that we use it. For example, if you are a participant taking part in the research we undertake, we will retain details of how much we paid you for up to seven years for accounting purposes. During the retention period we ensure the security and integrity of the information held. If you would like to know more about how long we hold your information please contact us.
Where your information is stored
Wherever possible, all the personal information we process is processed within the UK or European Economic Area (EEA). Some of our third-party service providers, for example our newsletter provider, are based outside the UK and EEA so their processing of your personal information will involve a transfer outside the UK and EEA.
Whenever we transfer your personal information outside of the UK or EEA, we do our best to make sure a similar degree of security of personal information by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission or ICO; or
- We may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which gives personal information the same protection it has in the UK and Europe.
You have a number of rights about how the personal information you provide to us can be used. These are:
- Transparency over how we use your personal information (right to be informed).
- The ability to request a copy of the information we hold about you, which will be provided to you within one month (right of access).
- Update or amend the information we hold about you if it is wrong (right of rectification).
- Ask us to stop using your information (right to restrict processing).
- Ask us to remove your personal information from our records (right to be ‘forgotten’).
- Object to the processing of your information for marketing purposes (right to object).
- Obtain and reuse your personal information for your own purposes (right to data portability).
- Not be subject to a decision when it is based on automated processing (automated decision making and profiling).
If you wish to raise a complaint about how we have handled your personal information, you can contact us, and we will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal information in accordance with the law, you may complain to the Information Commissioner’s Office (ICO).
If you would like to know more about your rights under data protection law, you can find out more at the Information Commissioner’s Office website.
Free Spirit Consulting Ltd. is a private limited company registered in England and Wales, Company Number 5994944, Registered address 34 Lower Richmond Road, Putney, London SW15 1JP
Last Reviewed: August 2021