Introduction

This Privacy Policy contains important information on how and why Azura SMG Limited [trading as AzuraMinds] collects, stores, uses and shares personal information, your rights in relation to your personal information as well as how to contact us and the supervisory authority in the event you have a complaint.

We are required to notify you of this information under the General Data Protection Regulation (GDPR). Please ensure you read this Privacy Policy and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

Personal data is any information relating to an identified or identifiable natural person. A natural person is considered to be identifiable if they can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, an identification number, location data, an online identifier or one or more special features.

By providing your personal information you acknowledge that we may use it in the ways set out in this Privacy Policy.

AzuraMinds may change this policy from time to time (for example, as a result of additions or changes to our services, government regulation, new technologies or other developments in privacy or data protection laws) and any such changes will be reflected here. Notwithstanding any change to this policy, we will continue to process your personal data in accordance with your rights and our obligations in law.

What this policy is about

This Privacy Policy explains how AzuraMinds processes your personal information (‘data’).

In this policy, “processes” means collects, stores, shares and otherwise uses for lawful purposes. “We” and “our” means AzuraMinds, and the policy covers all instances where we might process personal information of corporate clients or their employees, individual private clients, or other relevant parties of AzuraMinds.

This policy incorporates and reflects the new data protection legislation introduced in April 2018 called the General Data Protection Regulation (GDPR) and the Privacy and Electronic Communications Regulation (PECR).

If you have any questions about this policy or how we use your personal information, please contact us using the contact details set out below.

Organisations are permitted to process data if they have a legal basis for doing so. AzuraMinds processes personal data only in furtherance of their legitimate business objectives.

In the case of the business of AzuraMinds, the following apply:

• Express and informed consent has been given by the person whose data is being collected and processed; and/or
• It is necessary in relation to a contract or agreement which the person has entered into or because the person has asked for something to be done so they can enter into a contract or agreement.
• Where you have given express consent for the collection and processing of your personal data, it can be modified or withdrawn at any time by notifying us in writing, although this will affect the extent to which AzuraMinds is able to provide services to you or interact with you in future.

Our privacy principles

When we collect and use your personal information we ensure we look after it properly and use it in accordance with our privacy principles set out below:

• personal information you provide is processed fairly, lawfully and in a transparent manner
• personal information you provide is collected for a specific purpose and is not processed in a way that is incompatible with that purpose
• we only collect personal information that is relevant to the purposes for which it is required and processed
• your personal information is kept accurate and is updated where necessary
• your personal information is kept for no longer than is necessary for the purposes for which it is collected and processed
• we take appropriate steps to keep your personal information secure
• your personal information is processed in accordance with your rights
• we would never sell your personal information to a third party
• we would never profile your information – profiling is an automated process which uses publically available information to reach conclusions about supporters for marketing purposes

How we collect your personal information

We collect personal information directly from you:

• when you use or purchase our products or services
• via registration and application forms
• when you provide your details to us online or offline
• via cookies – (for further information see ‘Cookies and Other Similar Technologies’ below)

What personal information we collect

The personal information we collect about you will depend on your relationship with our business. It may include, but isn’t limited to:

• your name, address, telephone number, date of birth, gender and email address
• debit or credit card information, your bank account number, sort code and other banking information, information required to validate your identity and prevent fraud
• other information you provide to us from time to time which is relevant and necessary for us to collect and process
• using cookies, your activity online concerning your visit/s to our website and when we send you an email (for further information see ‘Cookies and Other Similar Technologies’ below)

How we use your personal information

We use your personal information for the following purposes:

• to confirm that any purchases have been processed correctly or to validate your identity
• to send you administrative notices relating directly to your interaction with AzuraMinds
• for our internal purposes such as management, research, analytics, organisational reporting, and ways that will improve efficiencies
• to create anonymised and aggregated reports as part of our legitimate business services
• to help the emergency services if required
• to comply with applicable laws, regulations, court orders, government and law enforcement agency requests, to operate our systems properly and to protect ourselves and our clients

Who we share your personal information with

• We do not sell or share personal details with third parties for the purposes of marketing
• We will not share any of your personal information with groups outside AzuraMinds other than for the purposes of providing our services to you
• When we share your information with other organisations such as data processors they are not allowed to use your information for their own purposes and they follow our instructions whilst complying with appropriate security measures
• We may also share your data with law enforcement agencies, regulators, courts, public authorities or emergency services if required to do so

How long do we keep records for

We will keep your personal information for as long as reasonably necessary in order to fulfil our services to you and to fulfil the relevant purposes set out in this Privacy Policy and in order to comply or demonstrate compliance with our legal and regulatory obligations.

The period for which we keep your information depends on the purpose for which your information was collected and the use.

We will not keep your personal information for longer than necessary for those purposes or for any other legal requirements.

Keeping your personal information up to date

We want to make sure that any personal information we hold about you is up to date. If you think your personal information is inaccurate, you can ask us to correct or remove it.  Please contact us if you would like to change any information that we may hold on you.

Under the GDPR, you have a right to know what personal information we hold about you. To request any information, please contact our Data Controller whose details are shown below, and we will make sure that this is handled in a swift and appropriate manner.

Your rights

The right to access your personal information

You are entitled to a copy of the personal information we hold about you and certain details of how we use it. There will not usually be a charge for dealing with these requests.

The right to rectification

We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case, please contact us and you can ask us to update or amend it.

The right to erasure

In certain circumstances, you have the right to ask us to erase your personal information, for example where the personal information we collected is no longer necessary for the purpose for which we have told you we will use it, or where you withdraw your consent if that is our legal ground for processing the information. However, this will need to be balanced against other factors, for example according to the type of personal information we hold about you and why we have collected it. There may be some legal and regulatory reason which means we cannot comply with your request.

In all cases we will either do as you have asked or explain why we are unable to, usually because of a legal or regulatory issue.

Cookies and other similar technologies

We use cookies to distinguish you from other users of our website and to collect and store information (which may include your personal information) about how you interact with our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Cookies are small text files placed on your device which uniquely identify your device. Cookies cannot be used to run programs or deliver viruses to your device.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make online payments.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences.

For more information about our use of these technologies please contact our assigned Data Protection Officer (DPO), Katherine Dennis, [email protected] +44 (0)7768 934931.

You have the right to raise any issues of concern about us regarding data protection and our processing of your information to the data protection regulator, The Information Commissioner’s Office (ICO).  (https://ico.org.uk/concerns/)