Privacy Policy

 Policy Introduction

Phil Badley Consulting Ltd (referred to here after as the company), also known under the branding Noble Octopus, is committed to data security and the fair and transparent processing of personal data. This privacy policy sets out how we will treat the personal data which you provide to us in compliance with applicable data protection law, and in particular, the General Data Protection Regulation (EU) 2016/679 (GDPR).

Please read this Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data, how to contact us and supervisory authorities if you would like to report a concern about the way in which we process your data.

For the purposes of the GDPR, Phil Badley Consulting Limited is the ‘controller’ of the personal data you provide to us.

If you have any queries about this Policy, the way in which the company processes personal data, or about exercising any of your rights, please send an email to Phil@diamondnine.co.uk

What personal data do we collect?

We may collect and process the following personal data:

Information you provide to us:

If you:

• we may collect your name, e-mail address, postal address, telephone number.
• correspond with us by phone, e-mail, or in writing;
• complete a form on our Website;
• sign up to receive our communications;
• enter a contract with us to receive products and/or services,
• complete a survey;
• report a problem;

We may also collect information on your visits to our website/Portal including (but not limited to) your IP address, browser, timestamp, location, country traffic data, location data, weblogs and other communication data and the resources that you access. This information will make your visit to our website/Portal easier in the future.

• we may also collect information for marketing purposes and analysis, including information on how your respond to email, sms, phone and other marketing campaigns;
• photos and videos of your attendance at training or similar sessions (you will be given a chance at the session to ask not to be videoed or photographed);
• details of any disabilities, or special dietary needs that you have in relation to venues, refreshments etc. that we may need to make for you at an event.

Information about other people

If you provide information to us about any person other than yourself, such as your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.

How do we use your personal data?

 When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any personal data we ask for is optional.

Contract performance: we may use your personal data to fulfil a contract, or take steps linked to a contract:

• to provide the products and/or services to you at your direct request or as a result of a request of a third party that the company is contracted to support;
• providing you with newsletters, surveys, information about our events, offers, and promotions, related to products and services offered by a member of the company which may be of interest to you;
• to communicate with you in relation to the provision of the contracted products and services;
• communicating with you in relation to any issues, complaints, or disputes;
• improving the quality of experience when you interact with our products and/or services.

Consent: where you have given your express consent to receive marketing communications, we may use your personal data to:

• send you newsletters, surveys, information about events, offers, and promotions, related to products and services offered by the company which may be of interest to you.

How long will you keep your personal data?

 The Company will keep your personal information for as long as you wish to receive our services and for up to 2 years thereafter.

Where you have consented to marketing communications, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us.

Where do we store your personal data and how is it protected?

We take reasonable steps to protect your personal data from loss or destruction.  We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

We may also share your personal data with trusted third parties including, company Associates, and relevant professional experts in such cases we will ensure that there is a contract in place with the categories of recipients listed above which include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.

Where a third party recipient is located outside the European Economic Area, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

Do we transfer your data to third parties?

 We may disclose your data to third parties i.e. to our Associates and suppliers. We may, for example, engage a supplier to carry out administrative and operational work in support of our relationship with you. The supplier(s) will be subject to contractual and other legal obligations to preserve the confidentiality of your data and to respect your privacy, and will only have access to the data they need to perform their functions.

Other Website Links
To provide increased value to users of our website, we may provide links to other websites or resources that are not part of the company. We do not exercise control over these websites or their privacy practices, and any information you provide is subject to the Privacy Policies of those websites, and not this Policy.

What are your rights?

• Right to access and obtain a copy of your personal information
  You are entitled to request confirmation whether we process any of your personal information.
• Right to correct your personal information
  If you can demonstrate that personal information we hold about you is not correct, you can request that this information is updated or otherwise corrected.
• Right to be forgotten/have data deleted
  In certain circumstances you have the right to request that we restrict the processing of your personal data and/or that your personal data is deleted.  You may make such a request at any time and we will evaluate if your request should be granted, however this right is subject to any legal rights or obligations we may have to retain data.  For situations where in accordance with the law, we determine that your request to have your personal information deleted must be granted, we will do so without undue delay.

• Right to object
  As far as the company’s processing of your data is based on the company’s legitimate interest (and no other processing ground) or relates to direct marketing, you are entitled to object to the Company processing your data by reference to your particular situation.

If you want to exercise any of your rights, please contact us via email Phil@diamondnine.co.uk

How do we handle changes to this Policy Statement?

This Policy may change from time to time. If we make material changes to this Policy, we will post any Policy changes on this page). Your continued use of our website and correspondence following such posts or notices will signal your acceptance of such changes.