1. INTRODUCTION
Pryor Wood Developments Ltd trading as Strategy Hat (“We”) are committed to safeguarding the privacy of our website visitors and customers. This policy (along with our terms of use document) explain how we will handle your personal data.
By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
For the purpose of the Data Protection Act 2018 and the UK GDPR, the data controller is Pryor Wood Developments Ltd of 110 Lodge Hill Road, Lower Bourne, Farnham, England, GU10 3RB (company No. 07978021).
2. THE TYPES OF PERSONAL DATA WE COLLECT ON YOU
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes [first name, last name, username or similar identifier].
- Contact Data includes [email address and telephone numbers].
- 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, device ID and other technology on the devices you use to access this website].
- Usage Data includes [information about how you interact with and use our website, products and services].
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
3. HOW WE USE YOUR PERSONAL DATA
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not 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).
- Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter
We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Use |
Type of data |
Legal basis [and retention period] |
To register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you [We will retain this data for a maximum of 4 years unless you request otherwise.] |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Dealing with your requests, complaints and queries |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you [We will retain this data for marketing purposes until you choose to opt-out. |
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) [We will retain this data for a maximum of 4 years unless you request otherwise.] |
You can ask us to stop sending you marketing communications at any time by contacting us using our website contact form: https://strategyhat.co.uk/contact/
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
4. PROVIDING YOUR PERSONAL DATA TO OTHERS
We may disclose your enquiry data to a third party supplier of services related to your enquiry to contact you with information we feel may interest you, if you have provided your explicit consent to our doing so. If you do not want us to pass your details on to a relevant third party service provider, please do not tick the box on the enquiry form.
In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for performance of a contract to which you are a party, for compliance with a legal obligation to which we are subject, or for other purposes specified by law.
5. RETAINING AND DELETING PERSONAL DATA
Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose and is stored on the backend of our website.
We will retain your personal data in accordance with the table set out at Section 3.2.
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on legal and regulatory requirements and with reference to the current and future value of the information.
6. AMENDMENTS
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
7. YOUR RIGHTS
You have a number of 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 “subject access request”): This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you: This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data in certain circumstances: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we 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 we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests): In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
- You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
- 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.
- Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 3.2 above for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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Request restriction of processing of your personal data: This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data’s accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us. See Our Contact Details (Section 10 below).
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, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you: We may need to request specific information from you to help us 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8. ABOUT COOKIES
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Please note that third parties (including advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.
Please see our Cookie Policy for further details of the cookies we use and for information on how to set, delete or otherwise manage them.
9. OTHER SITES
Our site may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check their policies before you submit any personal data on their websites.
10. OUR CONTACT DETAILS
This website is owned and operated by Pryor Wood Developments Ltd.
We are registered in England and Wales under registration number 07978021, and our registered office is at 110 Lodge Hill Road, Lower Bourne, Farnham, England, GU10 3RB.
You can contact us by using our website contact form: https://strategyhat.co.uk/contact/