the legal stuff
Privacy Notice
Kristina Rutherford Consulting Ltd
Privacy Notice
Kristina Rutherford Consulting Ltd respects your privacy and is committed to protecting your personal data. This privacy notice explains how we look after your personal data when you visit our website.
1. Purpose of this privacy notice
The purpose of this privacy notice is to give you information on how Kristina Rutherford Consulting Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign-up to our mailing list, purchase a product or service, take part in a competition, when you sign-up for any of our free offerings or complete a quiz.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements such other documents and is not intended to supersede them.
Controller
Kristina Rutherford Consulting Ltd is the controller and responsible for your personal data (collectively referred to as, "we", "us" or "our" in this privacy notice).
Contact details
If you have any questions about our privacy practices or this privacy notice, please contact us by email kristina@kristina-rutherford.com.
You have the right to make a complaint to the Information Commissioner's Office (ICO), the data protection regulator in the UK. We would, however, welcome the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance using the details provided.
Changes to the privacy policy and your duty to inform us of changes
Our privacy policy is regularly reviewed. This version was last updated on 15th March 2023 Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and up to date. Please let us know if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Using these links or enabling these connections may allow third parties to collect or share data about you. We do not have any control over those third-party websites and we do not have any responsibility for their privacy practices. When you leave our website, we recommend you read the privacy notice of the websites you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymous data where the identity has been removed.
We may collect, use, store and transfer different kinds of personal data about you:
• Identity Data includes first name, last name, username or similar identifier, title, date of birth, gender, photographs of you, and application forms.
• Contact Data includes billing address, delivery address, email address and telephone numbers, and business name.
• Financial Data includes bank account and payment details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• 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, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, survey and quiz responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as demographic or statistical data for different purposes. Aggregated Data can be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Furthermore, we do not collect any information about any criminal convictions or offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products and/or services). In this case, we may cancel a product and/or service you have with us, and we will notify you of such cancellation.
3. How is your personal data collected?
We use the following methods to collect data from and about you:
Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for or purchase our products and/or services;
• create an account on our website;
• subscribe to our publications or services;
• request information and marketing to be sent to you;
• participate in our competitions, promotions or surveys;
• sign-up for any of our free offerings; or
• provide us with feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy http://kristina-rutherford.com/legal-stuff for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
• Technical Data from the following parties:
(i) analytics providers such as Google Analytics based outside the UK;
(ii) advertising networks such as Affiliate Window based inside the UK; and
(iii) search information providers such as Google based outside the UK.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Excel Accounts Nowrich based inside and Thrivecart based outside the UK
4. How we use your personal data
We will only use your personal data when the law allows us to. We will most commonly use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
The types of lawful basis that we will rely on to process your personal data are explained in further detail, below:
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
We do not normally rely on consent as a legal basis for processing your personal data however, we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
The table below describes all of the ways we plan to use 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.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about the specific legal grounds we are relying on to process your personal data then please contact us. The table below identifies where there is more than one purpose for processing your personal data.
Marketing
We endeavour to provide you with options regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This enables us to identify which products, services and offers may be of interest to you (we call this marketing).
If you have requested information from us or purchased our goods, services or digital products you will receive marketing communications from us unless you have opted out of receiving that marketing.
Third-party marketing
We will only share your data with a third party for marketing services when we have your expressed opt-in consent to do so.
Opting out
You may ask us or third parties to stop sending you marketing messages at any time by following the opt-out or unsubscribe links on any marketing message sent to you.
Note when you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. When you disable or refuse cookies some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see http://kristina-rutherford.com/legal-stuff .
Change of purpose
Your personal data will only be used for the purposes for which we collected it., except when we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. At any time if you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
We will notify you and we will explain the legal basis which allows us to do so if we need to use your personal data for an unrelated purpose.
We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table in section 4 (above).
Internal Third Parties
We are not part of group of companies, therefore we do not share your personal data with other group companies.
External Third Parties:
Service providers based in United Kingdom who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third parties to which we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your purposes and in accordance with our instructions.
6. International transfers
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
If you would like further information on the specific mechanism used by us when transferring your personal data out of the UK, please contact us.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in relation to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the following data protection rights:
Your right of access to your personal data (commonly known as a "data subject access request"). This enables you to ask us for copies of the personal data we hold about you.
Your right of rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
Your right to request erasure of your personal data. 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.
Your right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Your right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Your right to 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.
Your right to withdraw consent at any time where we are relying on consent to process your personal 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.
If you wish to exercise any of the rights set out above, please email us at kristina@kristina-rutherford.co.uk
No fee usually required
We will not charge you 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, vexacious or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need 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 aim to respond to all legitimate requests within one month. Sometimes it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will keep you updated.
