Your personal data is important and so The Different Assistant is committed to doing its part to protect your personal data and comply with a range of safeguarding laws, including GDPR (General Data Protection Regulation).


This means that all personal data which I hold about you will be:

  •  ~  Used lawfully, fairly and in a transparent way.
  •  ~  Collected only for valid purposes that I have clearly explained to you and not used in any way that is incompatible with those purposes.
  •  ~  Relevant to the purposes I have told you about and limited only to those purposes.
  •  ~  Accurate and kept up to date.
  •  ~  Kept only as long as necessary for the purposes I have told you about.
  •  ~  Kept securely.

PURPOSE OF THIS PRIVACY POLICY


This Privacy Policy sets out how The Different Assistant collects and processes your personal data when you use this website.  This relates to your use of my website, whether you are using it to sign up to my newsletter, take part in a competition, or otherwise.


By visiting The Different Assistant and my associated domains (my “website”), and in particular by submitting your personal data to me, you are accepting and consenting to the practices described in this Privacy Policy.  This Privacy Policy applies whether you are visiting my website through an internet browser or through an “App” on your device.


The Different Assistant is committed to ensuring that your privacy is protected.  Should I ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.


It is important that you read this Privacy Policy together with any other privacy policy I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data.  This Privacy Policy supplements the other policies and is not intended to override them.


The Different Assistant may change this policy from time to time by updating this page.  You should check this page from time to time to ensure that you are happy with any changes.


This policy is effective from 16 January 2020.


Finally, my website is not intended for children and I do not knowingly collect data relating to children.


WHO I AM


I am The Different Assistant  (collectively referred to as “ The Different Assistant”, “I”, “my” or “me” in this Privacy Policy).


CONTACT DETAILS


If you would like to contact me regarding this Privacy Policy please use the details below or any relevant links provided on my website.


Email address: hello@thedifferentassistant.co.uk


PRIVACY COMPLAINTS PROCEDURE


You always have the right to make a complaint to the Information Commissioner’s Office (“ICO”) if you think your data is being misused.  The ICO is the UK’s supervisory authority for data protection issues (www.ico.org.uk).


I always appreciate the chance to try to deal with any data protection concerns before they are referred to the ICO so, if you are happy to do so, please do not hesitate to contact me using the details above so that I can try to help you out in the first instance.


CHANGE OF PURPOSE


I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose.  If you require more information, please contact me using the details above, which can also be found on my website.


If I need to use your personal data for an unrelated purpose, I will notify you.


Please note that I may process your personal data without your knowledge or consent where this is required or permitted by law.


It is important that the personal data I hold about you is accurate and current.


THIRD-PARTY LINKS


My website may contain links to and from third-party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third-parties to collect or share data about you.  Please check the relevant third-party privacy policies before you submit any personal data to them.


Please note that once you have used these links to leave my website, you should note that I do not have any control over that other website.  Therefore, I cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this privacy statement.  You should exercise caution and look at the privacy statement applicable to the website in question.


THE LAW


This Privacy Policy is governed by English law and you can bring legal proceedings in respect of it in the English courts.  If you live in Scotland you can bring legal proceedings in respect of it in either the Scottish or the English courts.  If you live in Northern Ireland you can bring legal proceedings in respect of it in either the Northern Irish or the English courts.


PERSONAL DATA


I may collect, use, store and transfer different kinds of personal data about you.  Including:

  •  ~  Your name, username or similar identifier, marital status, title, date of birth and gender (this will primarily be text based, but could also include audio, photos, videos and other forms of media).
  •  ~  Your contact address, email address and telephone numbers.
  •  ~  Your username and password, your interests, preferences, reviews, feedback and survey responses.
  •  ~  Information about how you use my website.
  •  ~  Your preferences in receiving marketing communications from me and our third-parties and your communication preferences.

I do not collect any special data that includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership and information about your health, genetic or biometric data, criminal convictions or offences.


Where I need to collect personal data by law, or under the terms of a contract I have with you, and you fail to provide that data when requested, I may not be able to perform the contract I have or are trying to enter into with.  In this case, I may have to cancel a service you have with me (but I will notify you if this is the case at the time).


DATA COLLECTION


I use different methods to collect data from and about you.


You may give me personal data by filling in forms or by corresponding with me by post, phone, email, by using my website, or otherwise, including but not limited to:

  •  ~  Information that you provide to me on my Social Media pages, such as Facebook, Twitter and Instagram.
  •  ~  Information that you provide when you enter one of my competitions or participate in one of my promotions.
  •  ~  Information that you provide when you report a problem with my website.
  •  ~  Information that you provide through surveys or when asked to give your opinions about my services and products.
  •  ~  Information that you provide when contacting or otherwise corresponding with me.

COOKIES


I may also receive Technical Data about you if you visit other websites employing my cookies.


I may receive data from various third-parties and public sources such as those set out below:

  •  ~  Data from analytics providers, advertising networks (such as Google AdWords / Google Shopping) and search information providers (all of which may be based outside the EU.

HOW I USE YOUR PERSONAL DATA


I collect your data to help determine your needs and provide you with a better service, and in particular for the following reasons:

  •  ~  To perform the contract I am about to enter into or have entered into with you in order to provide you with a service.
  •  ~  Internal record keeping.
  •  ~  I may use the information to improve my services.
  •  ~  I may periodically send promotional emails about new services, special offers or other information which I think you may find interesting using the email address which you have provided.
  •  ~  From time to time, I may also use your information to contact you for market research purposes. I may contact you by email or phone.
  •  ~  I may use the information to customise the website according to your interests.
  •  ~  I need to comply with a legal or regulatory obligation; and/or
  •  ~  You have specifically consented to me using your personal data in a particular way.

COOKIES POLICY


Cookies are small pieces of information that are stored on the hard drive of your device and they aid a server in collecting information from an internet browser.


I use cookies to:

  •  ~  Personalise my website to you.
  •  ~  Allow you to use my website in a way that makes your browsing experience more convenient.  For example, by allowing you to store items in an electronic shopping basket.
  •  ~  Place advertisements for my services on my website and other websites / apps involved in advertising or partnership networks in which I participate.
  •  ~  Personalise the advertisements which I place to you.
  •  ~  Make recommendations to you about services you might like.
  •  ~  Improve my website.  For example, knowing how my users navigate my website and use its features allows me to streamline the user experience, speed up searches, identify bugs, make enhancements and ultimately get you to the right page and product faster.
  •  ~  Review the popularity of my services and advertisements with reference to platform, location and other related factors.
  •  ~  Estimate my audience size and usage pattern.
  •  ~  Provide faster and more personal service by collecting information in respect of any accounts which you have on my website.
  •  ~  Collect anonymous data about the websites from which users have travelled to my website
  •  ~  Store information about any preferences which you set, so I can do things like greet you personally and speed up your login when you come back to my website.
  •  ~  Identify which of your device(s) you use to access my website or any account which you have registered on it.
  •  ~  Prevent credit fraud and various forms of cyber-crime.

The cookies I use:

  •  ~  May persist on your device between visits to my website, so that, for example, I can identify you when you visit again; and
  •  ~  May be provided either by me or by third-party service providers (such as analytics and search engine providers).

You can set your browser to accept or reject certain cookies or, if you prefer, you can set your browser to alert you each time a cookie is detected.  Previous cookies that have been stored on your device can also be deleted.  However, if you block our cookies or you subsequently delete a cookie that has been placed on your device, it will not be possible for you to use my website effectively as our systems rely on cookies to identify you as the user.


COOKIES I USE


Cookie Name Domain Purpose Duration
DSID .doubleclick.net Data Collection 2 weeks
IDE .doubleclick.net Data Collection 1 year
_ga .thedifferentassistant.co.uk Data Collection 2 years
_gat .thedifferentassistant.co.uk Data Collection 1 minute
_gid .thedifferentassistant.co.uk Data Collection 1 day
cookieconsent_status thedifferentassistant.co.uk Data Collection 1 year


DISCLOSURES OF YOUR PERSONAL DATA


I will NOT share your personal data with third-parties unnecessarily.  I may disclose your personal data for the purposes set out in this Privacy Policy:

  •  ~  If the possibility of such disclosure is otherwise stated in this Privacy Policy, my Terms of Use, my Terms and Conditions of Sale or otherwise when the personal data is collected from you. In particular, to the specific third-parties described in the tables in “How I use your personal data”.
  •  ~  To service providers acting as processors or joint controllers who provide me with IT and system administration services
  •  ~  To professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide me with consultancy, banking, legal, insurance and accounting services.
  •  ~  To HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
  •  ~  If I am under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect my rights, property, or safety, or the rights, property or safety of my customers, or others.  This includes exchanging information with the police or other investigatory or law enforcement authorities and companies and organisations involved in fraud protection and credit risk reduction.

I may also share anonymous data to third-parties such as my advertisers; and analytics and search engine providers that assist us in the improvement and optimisation of my website.


This anonymous data will be collected using cookies in a way which alone cannot identify any individual.


I will never share your personal data with any company outside The Different Assistant for non-The Different Assistant related marketing purposes.


INTERNATIONAL TRANSFERS


The data that I collect from you will be stored on secure servers within the European Economic Area (“EEA)”.  The majority of such data is held within the UK.


Certain information may be accessed and processed by staff operating outside the EEA who work for me or for one of my suppliers.  Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services (such as content moderation or the maintenance of our data storage facilities).


Whenever I transfer your personal data out of the EEA, I ensure a similar degree of protection is afforded to it.


DATA SECURITY


I 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 particular, I use SSL to encrypt your information.


I 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 I am legally required to do so.


Please note that, despite the steps I take, the transmission of information via the internet can never be completely secure.  Although I will do my best to protect your personal data, I cannot guarantee the security of your data transmitted to my website.


DATA RETENTION


I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.


To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.


By law I have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.  I typically retain this information for a further six to twelve months to ensure that no relevant claim has been made within that six year period before I dispose of it.


In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you.


YOUR LEGAL RIGHTS


Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact me using the details set out at the beginning of this Privacy Policy or using the contact details displayed on my website.


You can ask me or third-parties to stop sending you marketing communications at any time by using the “unsubscribe” link at the bottom of any marketing communications which I send to you; or by contacting me at any time using my contact details found at the top of this Privacy Policy, or on my website.


You have the right to request access to the personal data I hold about you and to check that I am lawfully processing it.  You also have the right to request correction of the personal data that I hold about you.  This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.


You have the right to request I erase your personal data.  This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it.  Please note, however, that I 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.


You have the right to object to me processing your personal data where I am 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.  In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.


You have the right to request I restrict the processing of your personal data.  This enables you to ask me to suspend the processing of your personal data if you want me to establish the data’s accuracy; where my use of the data is unlawful but you do not want me to erase it; where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.


You have the right to request I transfer your personal data to you or to a third-party. I 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 me to use or where I used the information to perform a contract with you.


You have the right to withdraw your consent to processing where I am relying on that 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, I may not be able to provide certain products or services to you.  I will advise you if this is the case at the time you withdraw your consent.


You will not have to pay a fee to access your personal data (or to exercise any of the other rights).  However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, I may refuse to comply with your request in these circumstances.


I may need to request specific information from you to help me 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.  I may also contact you to ask you for further information in relation to your request to speed up my response.


I try to respond to all legitimate requests within one month.  Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests.  In this case, I will notify you and keep you updated.

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