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1. OUR APPROACH

   1. This Privacy Policy (the “Policy”) sets out how we Red Castle Consultancy Ltd (company number: 11124624) headquartered at 11 Kingsway, Tiptree, Essex CO5 0LS (“our” or “we”), process the personal data of our website visitors and customers in the European Union (“User”).  

   2. If you have any questions about this Policy, please contact our team at redcastleconsultancy@gmail.com.

2. WHAT IS PERSONALLY IDENTIFIABLE INFORMATION (PII) / PERSONAL DATA?

3. Personal data or PII means any information relating to a person who can be identified either directly or indirectly; it may include name, address, email address, phone number, credit / debit card number, IP address, location data, purchase history (“Personal Data”).   

4. YOUR DUTY TO INFORM US OF CHANGES

5. It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us. 

6. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

1. We will only process your Personal Data, in accordance with applicable law, for the following purposes:

   1. creating and maintaining your Customer account, if you become our registered Customer; 

   2. granting access to our secure online portal, if you register for access;

   3. offering our goods and providing our services to you in a personalised way, for example, we may provide suggestions based on your previous searches to enable you to identify suitable goods and services quicker. This may also include, where legally permitted, processing data related to your location;

   4. handling and fulfilling your orders, if you request goods or services from us. This may also include processing of information that we receive from third parties, for example, address data to verify your correct address;

   5. obtaining payment from you, if you purchase any of our goods and/or services;

   6. enabling our suppliers and service providers to carry out certain functions on our behalf, including payment processing, verification, technical, logistical or other functions, as may be required, in order to fulfil your orders;

   7. resolving any returns, refunds or disputes, if you lawfully exercise your rights or if you wish to dispute any part of our offering; 

   8. making automated decisions and profiling in relation to your applications for our goods, for example, to check your eligibility for a certain products based on your past and current products with us and your usage of the same; 

   9. sending you personalised marketing communications, where you have agreed that we may do so, in order to keep you informed of our and our selected partner’s products and services, which we consider may be of interest to you;

   10. serving personalised advertising to your devices; delivering ads based on your interests ascertained from your past searches, visits of subpages and purchases on our websites, and other data obtained through the use of “cookies” placed on your devices. Please see our cookie policy ; 

   11. ensuring the security of your account and our business, preventing or detecting fraud or abuses of our website, for example, by requesting verification information in order to reset your account password;

   12. developing and improving our products and services, for example, by reviewing visits to our website and its various subpages, demand for specific goods and services and User comments; and

   13. to comply with applicable law, for example, in response to a request from a court or regulatory body, where such request is made in accordance with the law.

2. Your consent, as the Data Subject, to the processing as specified in this Policy is the primary legal ground for our processing of your Personal Data. However, there may be circumstances where we may also rely on other valid legal grounds for the processing of your Personal Data, such as:

   1. your request for content, goods or services necessitating steps including processing of your Personal Data to be taken prior to entering into contract with you and any processing that is necessary for the performance of such contract. This will include any profiling activities as set out in paragraph 4.1.8 that are necessary for the performance of a contract with us; and

   2. legitimate interests pursued by us as a business, except where such interests are overridden by your interests and fundamental rights. We will rely on this legal ground in relation to the processing set out in paragraphs 4.1.11 and 4.1.12, in which we have a legitimate interest; and

   3. compliance with a legal obligation to which we are subject, such as, for example, the processing for the purposes set out in paragraph 4.1.13.

3. DISCLOSURE OF CUSTOMER INFORMATION 

4. There are circumstances where we wish to disclose or are compelled to disclose your Personal Data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure: 

   1. to our subsidiaries, branches or associated offices;

   2. to our outsourced service providers or suppliers to facilitate the provision of our services or goods to our Users, for example, the disclosure to our data centre provider for the safe keeping of your Personal Data, webhosting provider through which your Personal Data may be collected, identity verification partners in order to verify your identity against public databases;

   3. to our advertising partners who enable us to deliver personalised ads to your devices or similar advertising;

   4. subject to your consent, to our marketing partners, who may contact you by post, email, telephone, SMS or by other means. If you do not wish to be contacted, you may unsubscribe by contacting our team at redcastleconsultancy@gmail.com.

   5. to third party service providers and consultants in order to protect the security or integrity of our business, including our databases and systems and for business continuity reasons;

   6. to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your Personal Data will be permanently transferred to a successor company; 

   7. to public authorities where we are required by law to do so; and

   8. to any other third party where you have provided your consent.

5. INTERNATIONAL TRANSFER OF PERSONAL DATA 

6. We may transfer your Personal Data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out in paragraph 2 above. In particular, your Personal Data may be transferred throughout our group and to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means.  Please contact the General Manager for a copy of the safeguards which we have put in place to protect your Personal Data and privacy rights in these circumstances. 

7. RETENTION OF PERSONAL DATA

1. Your Personal Data will be retained until your last use or purchase of our services or goods and normally for a period of three years thereafter, unless longer retention is required by applicable local law or where we have a legitimate and lawful purpose to do so. However, we will not retain beyond this period any of your Personal Data that is no longer required for the purposes set out in this Policy. The retention of your Personal Data will be subject to periodic review. 

2. We may keep an anonymised form of your Personal Data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

3. DATA SUBJECT RIGHTS 

1. Data protection law provides Data Subjects with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, their Personal Data.  Data Subjects also have the right to lodge a complaint with the relevant data protection authority if they believe that their Personal Data is not being processed in accordance with applicable data protection law. 

2. Right to make subject access request (SAR). Data Subjects may, where permitted by applicable law, request copies of their Personal Data.  If you would like to make a SAR, i.e. a request for copies of the Personal Data we hold about you, you may do so by writing to the team whose contact details are above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and a fee. 

3. Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete Personal Data.  

4. Right to withdraw consent. You may, as permitted by applicable law, withdraw your consent to the processing of your Personal Data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your Personal Data is essential. 

5. Right to object to processing. You may, as permitted by applicable law, request that we stop processing your Personal Data. 

6. Right to erasure. You may request that we erase your Personal Data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your Personal Data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations. 

7. Request the transfer of your personal data to you or to a third party. We 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 us to use or where we used the information to perform a contract with you.

8. Your right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your Personal Data. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website for instructions.

9. CHILDREN

   1. Please note that this website is not intended for children under the age of 16 and we do not knowingly collect data relating to children. 

10. LINKED WEBSITES

11. Please note that any websites that may be linked to our websites are subject to their own privacy policy. 

Cookie Policy

Cookies are a kind of short term memory for the web.  They are stored in your browser and enable a site to ‘remember’ little bits of information between pages or visits.

They are widely used to make the web experience more personal, which is generally seen as a positive thing. However some cookies collect data across many websites, creating ‘behavioural profiles’ of people. These profiles can then be used to decide what content or adverts to show you. This use of cookies for targeting in particular is what the law was designed to highlight. By requiring websites to inform and obtain consent from visitors it aims to give web users more control over their online privacy.