DICKS + NANTON CELEBRITY BRANDING® AGENCY and its affiliates and companies understand that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits our websites, https://esperanzamodev.wpengine.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
|“personal data”||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and, upon it becoming law, EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
|“We/Us/Our”||means Dicks + Nanton Celebrity Branding Agency, a limited liability company registered in the State of Florida under company number L07000008448,
whose registered address is 520 N Orlando Avenue #2, Winter Park, FL 32789, United States of America.
Information About Us
Our Site is owned and operated by Dicks + Nanton Celebrity Branding Agency, a limited liability company registered in the State of Florida under company number L07000008448, whose registered address is 520 N Orlando Avenue #2, Winter Park, FL 32789, United States of America.
Our core activities do not involve regular, systematic or large-scale monitoring of data subjects therefore we are not required to appoint a Data Protection Officer under GDPR, however if you have any queries in relation to Our use of your personal data or you wish to exercise any of your rights set out in section 4, please contact Us using the details in section 13.
What Does This Policy Cover?
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- the right to be informed about Our collection and use of personal data;
- the right of access to the personal data We hold about you (see section 12);
- the right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
- the right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
- the right to restrict (i.e. prevent) the processing of your personal data;
- the right to data portability (obtaining a copy of your personal data to re-use with another service or organization);
- the right to object to Us using your personal data for particular purposes; and
- rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
What Data Do We Collect?
We may receive personal information about you, when you use Our Site for example by doing any of the following:
- obtaining information about a product we offer, for example, a report, a book, an excerpt or chapter of a book or other information that We offer (Products);
- obtaining information about the keynote speaking, workshops and private advisory services that are offered on Our Site (Services);
- quoting and purchasing Products and Services from Us;
- using Our Site or any interactive services on Our Site; and/or
- telephoning, texting, writing by post or email, or communicating via online channels, such as online chat, to Us.
Depending upon your use of Our Site, We may collect some or all of the following personal data:
- business/company name;
- contact information such as email addresses and telephone numbers;
- your full address (or just post code, state and country);
- financial information such as credit / debit card numbers;
- reasons for your interest in Our Products or Services.
How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998 and, when it becomes law, GDPR at all times. For more details on security see section 7, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- supplying Our Products and Services to you (please note that We require your personal data in order to enter into a contract with you);
- personalizing and tailoring Our Products and Services for you;
- replying to emails from you;
- supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking on the unsubscribe option found in Our emails).
With your permission and/or where permitted by law, We may also occasionally use your data to contact you by email telephone and/or text message with carefully considered information, news or offers on Our Products and Services.
We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 and, when it becomes law, GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
We will keep the personal data referred to in section 5 for a period of up to 12 months after you first provided it to Us and if during that period you have not utilized or indicated interest in any of Our Products or Services or responded or acknowledged any of Our communications we will delete your personal data.
How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
Some or all of your data may be stored outside of the European Economic Area (EEA) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
You are deemed to accept and agree to this by using Our Site and submitting information to Us.
We take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 and, when it becomes law, GDPR.
We store your data using a client relationship management (CRM) system operated by Infusionsoft Inc. (a company based in Arizona, USA) (Infusionsoft).
Infusionsoft and its CRM system:
- use robust security measures described in more detail in Infusionsoft’s Data Security Statement which you can find at https://www.infusionsoft.com/legal/data-security;
- adhere to a Data Processing Addendum which you can find at https://www.infusionsoft.com/legal/dpawhich amounts to a guarantee that Infusionsoft will be GDPR compliant;
- adhere to an EU Model Contract approved by the European Commission which govern the lawful transfer of data from the EEA to countries outside of the EEA; and
- adheres to, and is audited annually for compliance with, the Payment Card Industry (PCI)Data Security Standard, which is a rigorous data protection framework oriented towards the protection of payment card data.
- Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
Steps We take to secure and protect your data include:
- all electronic copies of personal data should be stored securely using passwords and data encryption;
- all personal data stored electronically should be backed up in real time in accordance with Infusionsoft’s Data Security Statement referred to in section 7.6.1;
- no personal data should be stored on hard copies but if it becomes necessary to do so, it will be stored securely in a locked box, drawer, cabinet, or similar;
- no personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise; and
- no personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the Company that all suitable technical and organizational measures have been taken).
Do We Share Your Data?
We may sometimes contract with third parties to supply Our Products and Services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We use the following third-party data processor that is located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 and, when it becomes law, GDPR.
We use the following third-party data processors located outside of the EEA (each based in the USA) to transact payments for Products and Services and each processor guarantees that industry standard encryption protocols and practices are used to responsibly transmit sensitive information and are compliant with the PCI Data Security Standard:
- Net (CyberSource, Visa Inc.)
- PayPal (PayPal Holdings Inc.)
- QuickBooks(Intuit Inc.)
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
What Happens If Our Business Changes Hands?
How Can You Control Your Data?
In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your 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.
Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all. However, to access Products or Services and receive information available on Our Site you may be required to submit or allow for the collection of certain data.
How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held).
You may make subject access requests (“SARs”) at any time to find out more about the personal data which we hold about you, what we are doing with that personal data, and why.
We will provide any and all information in response to your request free of charge.