Updated: 25th May 2018
1. Privacy and your personal data
1.2 It applies to Information collected by us or provided by you over our website (including the mobile optimised version of the website accessible from your portable hand-held device) or in any other way (such as over the telephone). It is also intended to assist you in making informed decisions when using our website and services. Please take a minute to read and understand the policy.
1.3 All your personal Information shall be held and used in accordance with the EU General Data Protection Regulation 2016/679 ("GDPR") and national laws implementing GDPR and any legislation that replaces it in whole or in part and any other legislation relating to the protection of personal data. If you want to know what information we collect and hold about you, or to exercise any of your rights as set out in section 9 below, please write to us via email at firstname.lastname@example.org
1.4 Naomirich.com is the controller of your Information for the purposes of the GDPR.
2. What information do we collect on our website?
2.1 When you visit our website (including the mobile optimised version of the website accessible from your portable hand-held device) you may provide us with personal information such as name, email address, telephone number. You may provide us with Information in a number of ways:
a) by supplying us with the Information as listed above, on an individual basis, but you may also provide us with additional information if you choose to do so;
b) by corresponding with us by email, in which case we may retain the content of your email messages together with your email address and our responses;
c) through any preferences and areas of interest as advised by you on contacting us using our online contact us form; and
d) by Information provided when you use our mobile optimised website from your portable hand-held device including details of your physical location, where you have agreed to it being used.
2.2 We may collect Information about your computer, including where available your IP address, operating system, browser type and the geographical location of your computer, for system administration purposes. This is statistical data about browsing actions and patterns and does not identify you as an individual.
3. How we use your information
3.1 We will hold, use and disclose your Information for our legitimate business purposes including:
a) to keep you up to date about important changes to our business;
b) to advise you of news, industry updates and other information. Before we do so, you will be given an option to opt-out of such communications and an option to unsubscribe will also be provided with each communication;
c) to answer your queries;
d) to release Information to regulatory or law enforcement agencies, if we are required or permitted to do so.
3.2 When someone visits www.naomirich.com we may use a third party service, such as Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. This information is only processed in a way which does not identify anyone. We do not make, and do not allow our provider to make, any attempt to find out the identities of those visiting our website.
4. The legal basis for processing your information
4.1 Under GDPR, the main grounds that we rely upon in order to process your Information are the following:
a) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your Information. We may also be obliged by law to disclose your Information to a regulatory body or law enforcement agency;
b) Necessary for the purposes of legitimate interests - we, will need to process your information for the purposes of our legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your Information protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and customer experience, informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner;
c) Consent – in some circumstances, we may ask for your consent to process your Information in a particular way.
5. How we share your information
5.1 In certain circumstances we will share your Information with other parties. Details of those parties are set out below along with the reasons for sharing it.
a) Trusted third parties: In order to provide certain services, we will share your information with third party service providers such as IT infrastructure companies and email logistics providers. We will not share your data with any third party where it is not necessary to do so to provide a service to you.
b) Regulatory and law enforcement agencies. As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
c) New business owners. If we or our business merges with or is acquired by another business or company, we will share your personal information with the new owners of the business or company and their advisors. If this happens, you will be sent notice of such event.
6. How long we hold your information
We will only retain your Information for as long as is necessary for the purpose or purposes for which we have collected it. The criteria that we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept. For example, if we receive your Information when you apply for a job, we will retain your data for as long as is necessary to process your application and maintain application statistics. In certain circumstances, once we have deleted or anonymised your data, we may need to retain parts of it (for example, your email address), in order to comply with our obligations under GDPR or other legislation, or for fraud detection purposes.
7. Your rights relating to your Information
7.1 You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
a) Right of Access. You have the right at any time to ask us for a copy of the information about you that we hold, and to confirm the nature of the information and how it is used. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
b) Right of Correction or Completion. If information we hold about you is not accurate, or is out of date or incomplete, and requires amendment or correction you have a right to have the data rectified, updated or completed. You can let us know by contacting us at email@example.com.
c) Right of Erasure. In certain circumstances, you have the right to request that information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
d) Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your information by contacting us at firstname.lastname@example.org. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your information for direct marketing purposes. You may also have the right to restrict our use of your information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
e) Right of Data Portability. In certain instances, you have a right to receive any information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that information to you or directly to a third party organisation. This right exists in respect of Information that you have provided to us previously; and is processed by us using automated means. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation's systems. We are also unable to comply with requests that relate to information of others without their consent.
7.2 You can exercise any of the above rights by contacting us at email@example.com. You can exercise your rights free of charge.
7.3 Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
To the extent that we are processing your information based on your consent, you have the right to withdraw your consent at any time. You can do this by unsubscribing via the link provided in any direct marketing communication, or contacting us at firstname.lastname@example.org.
If you are unhappy about our use of your information, you can contact us at email@example.com. You are also entitled to lodge a complaint with the UK Information Commissioner's Office using any of the contact methods below:
Information Commissioner's Office
T: 0303 123 11113W: