Privacy Policy
Quick Jump
I take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who I am and how and why I collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact me or supervisory authorities in the event you have a complaint.
I collect, use and are responsible for certain personal data about you. When I do so I am subject to the UK General Data Protection Regulation (UK GDPR). I am also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services I offer to individuals in the European Economic Area (EEA).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
Stephanie Holland trading as Mangala Holland
Any information relating to an identified or identifiable individual
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data (when processed to uniquely identify an individual)
Data concerning health, sex life or sexual orientation
The individual who the personal data relates to
Personal data I collect about you
I may collect and use the following personal data about you:
- your name and contact
- information, including email address and telephone number
- information to check and verify your identity, e.g. your date of birth
- your gender
- location data
- your billing information, transaction and payment card information
I collect and use this personal data to provide services to you. If you do not provide personal data I ask for, it may delay or prevent me from providing services to you.
How your personal data is collected
I collect most of this personal data directly from you—in person, by Zoom or other online
communication, telephone, text or email. However, I may also collect information:
- from publicly accessible sources, e.g. Companies House;
- directly from a third party, e.g: credit reference agencies;
- from a third party with your consent, e.g. your bank or building society
How and why I use your personal data
Under data protection law, I can only use your personal data if I have a proper reason, e.g:
- where you have given consent;
- to comply with our legal and/or regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for my legitimate interests or those of a third party.
A legitimate interest is when I have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. I will carry out an assessment when relying on legitimate interests, to balance my interests against your own.
The accordion below explains what I use your personal data for and why.
To perform my contract with you or to take steps at your request before entering into a contract
For my legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or me
To comply with my legal and/or regulatory obligations
For my legitimate interests or those of a third party, i.e. to make sure I am following my own internal procedures so I can deliver the best service to you
For my legitimate interests or those of a third party, i.e. to be as efficient as I can so I can deliver the best service to you at the best price
For my legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information.
To comply with my legal and/or regulatory obligationsÂ
E.g. in relation to my financial performance, customer base, product range or other efficiency measures.
For my legitimate interests or those of a third party, i.e. to be as efficient as I can so I can deliver the best service to you at the best price
For my legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or me.
To comply with my legal and/or regulatory obligations
To perform my contract with you or to take steps at your request before entering into a contract
To comply with my legal and/or regulatory obligations
For my legitimate interests or those of a third party, e.g. making sure that I can keep in touch with my customers about existing orders and new products
To comply with my legal and/or regulatory obligations
To comply with my legal and regulatory obligations.
For my legitimate interests or those of a third party, e.g. to make sure I am following my own internal procedures and working efficiently so I can deliver the best service to you
To:
- existing and former customers;
- third parties who have previously expressed an interest in my services;
- third parties with whom I have had no previous dealings.
For my legitimate interests or those of a third party, i.e. to promote my business to existing and former customers
For my legitimate interests or those of a third party, i.e. to ensure my customers are likely to be able to pay for my products and services
Eg: for ISO or Investors in People accreditation and the audit of my accounts.
Where I process special category personal data, I will also ensure I am permitted to do so under data protection laws, e.g:
- I have your explicit consent;
- the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
- the processing is necessary to establish, exercise or defend legal claims.
Marketing
I may use your personal data to send you updates (by email, text message, telephone or post) about my services, including exclusive offers, promotions or new services.
I have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why I use your personal data’). This means I do not usually need your consent to send you marketing information. However, where consent is needed, I will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by contacting me at mangala@mangalaholland.com;
I may ask you to confirm or update your marketing preferences if you ask me to provide further services in the future, or if there are changes in the law, regulation, or the structure of my business.
I will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
Who I share your personal data with
I routinely share personal data with:
- third parties I use to help deliver my services to you, e.g. payment service providers, warehouses and delivery companies;
- other third parties I use to help me run my business, e.g. marketing agencies or website hosts;
- third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
- credit reference agencies;
I only allow my service providers to handle your personal data if I am satisfied they take appropriate measures to protect your personal data. I also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to me and to you.
I may also need to:
- share personal data with external auditors, e.g. in relation to ISO accreditation and the audit of my accounts;
- disclose and exchange information with law enforcement agencies and regulatory bodies to comply with my legal and regulatory obligations;
- share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who I share data with and why, please contact me (see ‘How to contact me’ below).
I will not share your personal data with any other third party
Where your personal data is held
Personal data may be held at my offices and those of my third party agencies, service providers, representatives and agents as described above (see above: ‘Who I share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how I safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data will be kept
I will keep your personal data while you have an account with me or I am providing services to you. Thereafter, I will keep your personal data for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that I treated you fairly;
- to keep records required by law.
I will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data.
When it is no longer necessary to keep your personal data, I will delete or anonymise it.
Transferring your personal data out of the UK and EEA
To deliver services to you, it is sometimes necessary for me to share your personal data outside the UK/EEA, e.g:
- with your and my service providers located outside the UK/EEA;
- if you are based outside the UK/EEA;
- where there is a European and/or international dimension to the services I am providing to you.
Under data protection law, I can only transfer your personal data to a country or international
organisation outside the UK/EEA where:
- the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
- a specific exception applies under data protection law
These are explained below
Adequacy decision
I may transfer your personal data to certain countries, on the basis of an adequacy decision.
These include:
- all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
- Gibraltar; and
- Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. I will always seek to rely on an adequacy decision, where one exists.
Other countries or international organisations I am likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but I must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, I may transfer your personal data to another country or international organisation if I am satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using legally-approved standard data protection contract clauses.
To obtain a copy of the standard data protection contract clauses and further information about relevant safeguards, please contact me (see ‘How to contact me’ below).
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, I may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, e.g:
- you have explicitly consented to the proposed transfer after having been informed of the possible risks;
- the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
- the transfer is necessary for a contract in your interests, between me and another person; or
- the transfer is necessary to establish, exercise or defend legal claims
I may also transfer information for the purpose of my compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and I will provide relevant information if and when I seek to transfer your personal data on this ground.
Further information
If you would like further information about data transferred outside the UK/EEA, please contact me (see ‘How to contact me’ below).
Your rights
You have the following rights, which you can exercise free of charge:
The right to be provided with a copy of your personal data
The right to require me to correct any mistakes in your personal data
The right to require me to delete your personal data—in certain situations
The right to require me to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
The right to receive the personal data you provided to me, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
The right to object:
- at any time to your personal data being processed for direct marketing (including profiling);
- in certain other situations to my continued processing of your personal data, e.g. processing carried out for the purpose of my legitimate interests.
For further information on each of those rights, including the circumstances in which they apply, please contact me (see ‘How to contact me’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
email, call or write to me—see below: ‘How to contact me’; and
provide enough information to identify yourself and any additional identity information I may reasonably request from you;
let me know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
I have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. I limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
I also have procedures in place to deal with any suspected data security breach. I will notify you and any applicable regulator of a suspected data security breach where I am legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact me if you have any query or concern about our use of your information (see below ‘How to contact me’). I hope I will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at ico.org.uk or telephone: 0303 123 1113.
Changes to this privacy policy
This privacy notice was published on 14/01/21 and last updated on 14/01/21
I may change this privacy notice from time to time—when I do I will inform you via email.
How to contact me
Individuals in the UK
You can contact me by post, email or telephone if you have any questions about this privacy policy or the information I hold about you, to exercise a right under data protection law or to make a complaint.
My contact details are shown below:
PO Box 3455, Bristol, UK BS5 5HS
mangala@mangalaholland.com
+44 (0) 782 1810679
Individuals in the EEA
We have appointed
GDPREP.ORG
to be our data protection representative within the EEA. Their contact details are:
Suite 10357, 5 Fitzwilliam Square, Dublin 2, Ireland, D02 R744
+44 (0) 7810 883333
Individuals within the EEA can contact us direct (see above) or contact our European representative.
