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Privacy Policy

Policy version 20 October 2022

 

Arpita Dutt Consulting Limited (our website) is provided by Arpita Dutt Consulting Limited (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

 

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

 

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals.

 

Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.

 

This version of our privacy policy is primarily written for adults, including parents and guardians of child users. If you are a child (under 18 years old) you are welcome to read this policy if you find it useful. This privacy policy is divided into the following sections: 

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•    What this policy applies to

•    Personal data we collect about you

•    How your personal data is collected

•    How and why we use your personal data

•    Marketing

•    Who we share your personal data with

•    How long your personal data will be kept

•    Transferring your personal data out of the UK and EEA

•    Cookies and other tracking technologies

•    Your rights

•    Keeping your personal data secure

•    How to complain

•    Changes to this privacy policy

•    How to contact us

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What this policy applies to

 

This privacy policy relates to your use of our website only.

 

Throughout our website we may link to other websites owned and operated by certain trusted third parties to direct you to related information and provide other services to you. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.

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Personal data we collect about you

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The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you: 

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•    your name, address and contact information, including email address and telephone number and company details

•    any delivery addresses specified for your order

•    information to check and verify your identity, e.g. date of birth

•    your gender, if you choose to give this to us

•    location data, if you choose to give this to us

•    your billing information, transaction and payment card or other payment method information

•    bank account and payment details

•    details of any information, feedback or other matters you give to us by phone, email, post or via social media

•    your account details, such as username and login details

•    your activities on, and use of, our website

•    your personal or professional interests

•    your professional online presence, eg LinkedIn profile

•    information about the services we provide to you

•    your contact history, purchase history and saved items

•    information about how you use our website and technology systems

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You must provide this personal data to use our website and the services on it unless we tell you that you have a choice.  

 

Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website or any services on it. 

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We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

 

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How your personal data is collected

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We collect personal data from you:  

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•    directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase services via our website, post material to our website and forms via our website, and

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•    indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explain in the section on ‘Cookies and other tracking technologies’ below

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How and why we use your personal data 


Under data protection law, we can only use your personal data if we have a proper reason, eg: 

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•    where you have given consent

•    to comply with our legal and regulatory obligations

•    for the performance of a contract with you or to take steps at your request before entering into a contract, or

•    for our legitimate interests or those of a third party

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A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

 

The table below explains what we use your personal data for and why. 

Create and manage your account with us 

For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price  

 

and

 

To perform our contract with you or to take steps at your request before entering into a contract 

Providing services to you 

To perform our contract with you or to take steps at your request before entering into a contract 

Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us 

To comply with our legal and regulatory obligations

 

OR 

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For our legitimate interests, ie to minimise fraud that could be damaging for you and/or us 

To enforce legal rights or defend or undertake legal proceedings 

Depending on the circumstances:

 

— to comply with our legal and regulatory obligations

 

— in other cases, for our legitimate interests, ie to protect our business, interests and rights 

What we use your personal data for 

Our reasons 

Customise our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website 

Depending on the circumstances:

 

—your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below

 

—where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

 

If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool and add appropriate links (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) 

Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended 

Depending on the circumstances:

 

—your consent as gathered by the separate cookies tool on our website—see ‘Cookies and other tracking technologies’ below

 

—where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price

 

If you have provided such a consent you may withdraw it at any time (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) 

Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices 

Depending on the circumstances: 

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—to comply with our legal and regulatory obligations

 

—in other cases, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price 

Protecting the security of systems and data used to provide the services 

To comply with our legal and regulatory obligations

 

We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us 

Statistical analysis to help us understand our customer base 

For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price 

Updating and enhancing customer records 

Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products 

Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant 

To comply with our legal and regulatory obligations 

Marketing our services to existing and former customers  

For our legitimate interests, ie to promote our business to existing and former customers See ‘Marketing’ below for further information 

The audit of mediation services (to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above) 

For our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards 

To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency

 

In such cases information will be anonymised 

Depending on the circumstances:

 

—to comply with our legal and regulatory obligations

 

—in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets 

How and why we use your personal data—in more detail 

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More details about how we use your personal data and why are set out in the table below:

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Purpose 

Processing operation 

Lawful basis relied on under the UK GDPR and EU GDPR 

Relevant categories of personal data 

Communications with you not related to marketing, including about changes to our terms or policies or changes to the products or other important notices 

Addressing and sending communications to you as required by data protection laws, i.e.: —the UK GDPR or Data Protection Act 2018 —the EU GDPR 

Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) 

—your name, address and contact information, including email address and telephone number and company details, billing information

 

—your account details (username) 

Addressing and sending communications to you as required 

Processing is necessary for compliance with a legal obligation to which we are subject (Article 6(1)(b)) 

As above 

Addressing and sending communications to you about changes to our terms or policies or changes to the products or other important notices (other than those addressed above)

Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you 

As above 

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

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We routinely share personal data with: 

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•    third parties we use to help deliver our services to you, e.g. payment service providers

•    other third parties we use to help us run our business, eg marketing agencies or website hosts and website analytics providers

•    our bank

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We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.  

 

We or the third parties mentioned above occasionally also share personal data with: 

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•    our and their external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations

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•    our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations

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•    law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations

 

•    other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations

Who we share your personal data with—in more detail 

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More details about who we share your personal data with and why are set out in the table below.

Recipient 

Processing operation (use) by recipient 

Relevant categories of personal data transferred to recipient 

Wix 

Web and data hosting services, i.e. stores a copy of your personal data on computer equipment so it can be accessed by us and permitted third parties (see below) online.

Hosting company: Any of the necessary personal data we collect about you  

Stripe 

Payment services. 

Bank account and payment details. 

We will not share your personal data with any other third party. 

Who we share your personal data with—further information

 

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

 

 

How long your personal data will be kept

 

We will not keep your personal data for longer than we need it for the purpose for which it is used.

 

Different retention periods apply for different types of personal data.  

 

If you stop using your account we will delete or anonymise your account data after seven years.

 

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

 

 

Transferring your personal data out of the UK and EEA

 

The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

 

It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.

 

We will transfer your personal data to: 

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•    our service providers located outside the UK to WIX and to Stripe, and

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As we are based in the UK we will also transfer your personal data from the EEA to the UK.

 

Under data protection laws, we can only transfer your personal data to a country outside the UK[/EEA] where: 

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•    in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.

 

•    in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here.

 

•    Privacy Shield Certification: Our website is hosted by a third party, Wix. Wix and its affiliates, including DeviantArt Inc., participates in, and has certified its compliance with, the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List, here. In compliance with the Privacy Shield Principles, Wix.com commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact: privacy@wix.com. For the avoidance of doubt, Wix does not rely on the Privacy Shield as a mechanism for transferring GDPR protected personal data.

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•    there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or

 

•    a specific exception applies under relevant data protection law

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Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) [insert transfer mechanism, eg legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR]. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.

 

Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available). In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.

 

Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

 

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Transferring your personal data out of the UK[ and EEA]—further information

 

If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below). Cookies and other tracking technologies A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website.

 

 

We use cookies on our website.

 

These cookies help us recognise you and your device and store some information about your preferences or past actions.

 

 

Your rights

 

You generally have the following rights, which you can usually exercise free of charge: 

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Access to a copy of your personal data 

The right to be provided with a copy of your personal data

 

A more detailed explanation of this right under UK law is available here 

Correction (also known as rectification) 

The right to require us to correct any mistakes in your personal data

 

A more detailed explanation of this right under UK law is available here 

Erasure (also known as the right to be forgotten) 

The right to require us to delete your personal data—in certain situations 

 

A more detailed explanation of this right under UK law is available here 

Restriction of use 

The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data

 

A more detailed explanation of this right under UK law is available here 

Data portability 

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

 

A more detailed explanation of this right under UK law is available here 

To object to use 

The right to object:

 

—at any time to your personal data being used for direct marketing (including profiling)

 

—in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims

 

A more detailed explanation of this right under UK law is available here 

The right to withdraw consents 

If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time

 

You may withdraw consents by writing to.

 

Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn  

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.  

 

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please: 

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•    provide enough information to identify yourself e.g. your full name, email address and telephone contact number and any additional identity information we may reasonably request from you, and

 

•    let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

 

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.  

 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

If you want detailed information from Get Safe Online on how to protect your personal data and other 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 us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

 

You also have the right to lodge a complaint with: 

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•    the Information Commissioner in the UK

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The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

 

 

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Changes to this privacy policy

 

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example, by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email. 

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•    the Information Commissioner in the UK

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The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

 

 

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Changes to this privacy policy

 

We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example, by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email. 

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How to contact us

 

Individuals in the UK You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

 

Our contact details are shown below: 

Our contact details 

Our Data Protection Officer’s contact details 

Arpita Dutt Consulting Limited arpita@arpitadutt.com

07880790538 

86-90 Paul Street, London EC2A4NE

arpita@arpitadutt.com

07880790538 

Do you need extra help?

 

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above). 

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