Positively Uncomfortable Consulting

NOKAMO.COM PRIVACY POLICY

Background

Nokamo Consultancy 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.nokamo.com 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.

Information about us

Our Site is owned and operated by Nokamo Consultancy Ltd, a limited company registered in England & Wales No.12231685 with its registered and main trading address at Bennetts Hill House, 24 Bennetts Hill, Birmingham, B2 5QP. VAT number: 336 2837 90.

Scope

This statement applies to the following:

  • Personal information we collect through our website.

  • Personal information we collect about you in the course of doing business with you, such as when you engage with us as a customer, potential customer, supplier, service provider, professional advisor, consultant or other third party in relation to the provision of our services and the operation of our business generally

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 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.

Your rights


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

  1. 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 contact details shown at the end of this document

  2. The right to access the personal data we hold about you. You’ll find instructions on how to do this further on in this policy

  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. If you need to do this, you can contact us using the details provided at the end of this policy

  4. 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. If you want to do this, you can contact us using the details provided at the end of this policy

  5. The right to restrict (i.e. prevent) the processing of your personal data.

  6. The right to object to us using your personal data for a particular purpose or purposes

  7. 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

  8. 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

  9. 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 at the end of this policy.

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 provided at the end of this policy.

Information we collect from you

Depending on your use of Our Site, we may collect and process personal and non-personal data about you.  We do not collect any sensitive personal data or personal data relating to children or data relating to criminal convictions or offences.

Information you provide to us through our website

This is information about you that you give us by filling in forms on www.nokamo.com  (our site). The information you give us may include your name, address, e-mail address, phone number and details of your business activities.

You can choose not to provide this information by not entering it when prompted to do so. If you do not provide us with some or all of the requested information, we may not be able to provide the requested information or service to you.

You may choose to provide personal information when engaging in or conducting business with us. The types of information we may collect include names, email addresses, postal addresses, contact details, job titles, transactional information, financial/billing information, account information, correspondence and any other information you may choose to provide.

Other information we collect in the course of operating our business

We also collect information from our suppliers, service providers, agents, consultants, business partners, professional advisors and other third parties for the purpose of managing and operating our business.

How we use the information

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

  • to carry out our obligations arising from any contracts/agreements entered into between you and us and to provide you with the information and services that you request from us

  • to provide you with information about events and services we think may be of interest to you

  • to process and complete business transactions and send related information, including transaction confirmation and invoices

  • to notify you about changes to our service

  • to ensure that content from our site is presented in the most effective manner for you and for your computer

If we are not able to process your personal data whether because you do not consent, you withdraw or limit consent, or for any other reason then we will not be able to achieve the purposes listed above.

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, telephone or post with information, news, and offers on our 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 not share your personal data with third parties for marketing purposes.

We will only use your personal data for the purpose(s) for which it was originally collected.

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.

Automated decision making

We do not use automated decision making, including profiling.

Retention of 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. Your personal data will therefore be retained for as long as we deem reasonable for the purpose of carrying out the agreed business with you.

Where we store your data

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

Please contact us using the details provided at the end of this policy for further information about the particular data protection mechanisms 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 legally required to do so

Disclosure of your information

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

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 business may continue to use your personal data in the same way(s) that we have used it, as specified in this 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.

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.

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.

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.

Withholding information

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

How to access your 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 or postal addresses provided at the end of this policy.

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 21 days and, in any case, not more than 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.

Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

Like many sites, we use cookies to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our site.


How we use cookies

Our site uses analytics services provided by Google. 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 services offered through it.

The analytics service used by Our Site uses Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst 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.


Contact Details

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 Rachel Deacon:

Email: rachel.d@nokamo.com 

Telephone: 020 3006 2100

Postal Address: NOKAMO, Bennetts Hill House, 24, Bennetts Hill, Birmingham, England, B2 5QP

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 on 22nd January 2020.