BACKGROUND:

EJH Consulting Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.applypsychology.co.uk  (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

 

Please read this Privacy Policy carefully and ensure that you understand it.

 

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Site is owned and operated by EJH Consulting Ltd t/a Apply Psychology, a limited company registered in England under company number 05611285.

Registered address: 10 Moorend Grove, Leckhampton, Cheltenham, Gloucestershire, GL53 0EZ.

Data Protection Officer: Emily Hutchinson.

Email address: hello@applypsychology.co.uk

Telephone number: 07763 187382

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
• The right to access the personal data we hold about you. Part 13 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first, using the details in Part 15.

6. What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’, ‘sensitive’ personal data, personal data relating to children, or data relating to criminal convictions or offences.

Data Collected		How we Collect the Data
Identity Data may include your first name, last name, username, title, date of birth and gender.		Sign-up processes. Contracting. Publicly available sources. Providers of technical, payment and delivery services.
Contact Data may include your billing address, delivery address, email address and telephone numbers.		Sign-up processes. Contracting. Publicly available sources. Providers of technical, payment and delivery services.
Financial and Transactional Data may include your bank account and payment card details and details about payments between us and other details of purchases made by you.		Contracting. Providers of technical, payment and delivery services.
Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.		Website analytics. Providers of technical, payment and delivery services.
Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.		Feedback forms, surveys, research and evaluations. Purchases and orders of our products and services. Providers of technical, payment and delivery services.
Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.		Sign-up processes. Providers of marketing platforms.
Usage Data may include information about how you use our website, products and services.		Website analytics.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.		Website analytics.

 

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do		What Data We Use		Our Lawful Basis
Registering you on Our Site or as a new customer / client, to provide a product/service and to manage our relationship with you.		Identity. Contact. Profile.		Performance of a contract with you. Necessary to comply with legal obligation. Necessary for legitimate interests to keep our records updated or to learn how customers use our products/services.
Administering and protecting Our Site and business.		Identity. Contact. Profile. Technical.		Necessary for legitimate interests for running our business, provision of administration and IT services, to prevent fraud, and to comply with legal obligation.
Managing payments for our products and services.		Identity. Contact. Transaction. Financial. Marketing and communications.		Necessary for our legitimate interests to recover any debts owed to us.
Relevant content and advertisements and to measure and understand the effectiveness of our advertising.		Identity. Contact. Profile. Usage. Marketing and communications. Technical.		Necessary for legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.
Data analytics to improve Our Site, products/services, marketing, customer relationships and experiences.		Technical. Usage.		Necessary for legitimate interests to define types of customers for our products/services, to keep Our Site up to date, to develop our business and to inform our marketing strategy.
To make suggestions and recommendations to you about products/services that may be of interest to you.		Identity. Contact. Technical. Usage. Profile.		Necessary for our legitimate interests to develop our products/services and to grow our business.
Communicating with you, to notify you of changes to our terms or privacy policy, to ask you to leave a review, feedback or take a survey.		Identity. Contact. Profile. Marketing and communication.		Performance of contract with you. Necessary to comply with a legal obligation. For our legitimate interests to keep our records up to date and study how customers use our products/services.
To enable you to take part in a prize draw, competition or complete a survey.		Identity. Contact. Profile. Usage. Marketing and communication.		Performance of a contract with you. For our legitimate interests to study how our customers use our products/services, to develop them and to grow our business.

 

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In order to determine the retention period for personal data, we consider the nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of personal data, the purposes for which your data is processed, whether we can process the data through other means and any applicable legal requirements.

By law we keep basic information about customers for six years after they cease being customers for tax purposes. This includes Contact, Identity, Financial and Transaction data.

There are some circumstances where you can ask us to delete your data, see Part 5.

In some situations, we may anonymise your personal data for statistical or research purposes. The data will no longer be associated with you and we can use the information indefinitely without further notice to you.

9. How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We share your data with external third parties, as detailed below in Part 10, with some based outside of the EEA. The following safeguards are applied to such transfers:

We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission.

Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may sometimes contract with the following third parties to supply certain products and/or services, such as our CRM, contract signing software, back-up cloud server, marketing systems and ecommerce platforms, which are necessary for the running of our business and to supply our products/services.

Your personal data will be shared with an administration team who provides support to our business. We only allow the administration team to process your personal data for specified purposes, such as, those necessary for the performance of our contract with you, to manage our working relationship with you and to administer our business services and products.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11. How Can I Control My Personal Data?
    • In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details).
    • You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?

You may access areas of Our Site without providing any personal data at all. You may restrict our use of Cookies. For more information, see Part 14.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email address shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a Privacy Policy and Cookie Policy pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

The following first-party Cookies may be placed on your computer or device:

Name of Cookie		Expiration Time		Purpose
wordpress_logged_in_		When browser closes		WordPress uses this cookie when you’re logged in to determine that you are successfully logged in
wordpress_sec_		When browser closes		WordPress uses this cookie when you’re logged in to determine that you are successfully logged in
wordpress_test_cookie		When browser closes		WordPress sets this cookie when you navigate to the login page. This checks if your browser is set to allow cookies.
wp-settings-		1 year		Used to customise your view of our site when logged in
wp-settings-time-		1 year		Used to customise your view of our site when logged in

Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.

The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

The analytics service(s) used by Our Site use(s) the following Cookies:

Name of Cookie		Provider		Purpose
_ga		Google Analytics		Used to distinguish users.
_gid		Google Analytics		Used to distinguish users.
_gat		Google Analytics		Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.
AMP_TOKEN		Google Analytics		Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
_gac_<property-id>		Google Analytics		Contains campaign related information for the user. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out. Learn more.

 

Other Website Integrations and Plug-Ins:

Mailchimp		Our Mailchimp (The Rocket Science Group, LLC) integration uses cookies, which we use to manage email marketing subscriber lists and send emails to our subscribers. Read their cookie policy.
AddToAny Share Buttons		Our AddToAny Share Buttons plugin for WordPress, increases traffic and engagement through our website by helping people share our posts and pages to any service. Services can include Facebook, Twitter, Pinterest, WhatsApp, LinkedIn, Tumblr, Reddit, WeChat, and other more sharing and social media sites and apps. Read their privacy policy here.

 

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Emily Hutchinson:

Email address: hello@applypsychology.co.uk

16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated in September 2020.