Privacy Policy

Background

Nomipalony understands that your privacy is important to you and that you care about how your information is used and shared. We will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.

This Policy applies to our use of any and all data collected by us in relation to your use of our business, both Our Site and in email/social media interactions. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
Our Site” means this website, www.nomipalony.com;
“UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
“We/Us/Our” means Nomipalony, a sole trader

 

2. Information About Us

  • Our Site, www.nomipalony.com, is owned and operated by Nomipalony, a sole trader, whose address is Unit 16808, PO Box 6945, London, W1A 6US
  • We are regulated by the Advertising Standards Authority
  • ICO registration number is A8324966
  • Data Protection Officer: Nyomi Winter
  • Email address: [email protected]

3. Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site and our business interactions, for example, email and social media correspondence. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Data Do We Collect?

Some data will be collected automatically by Our Site (for further details, please see section 13 on Our use of Cookies and Our Cookie Policy https://nomipalony.com/cookie-policy) other data will only be collected if you voluntarily submit it. We may collect some or all of the following data:

  • name;
  • business/company name;
  • job title;
  • contact information such as email addresses and telephone numbers;
  • IP address (automatically collected);
  • web browser type and version (automatically collected);
  • operating system (automatically collected);
  • a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection. An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

5. The lawful basis for processing your data

  • We process your personal data under, ‘article f – legitimate interest’, ‘article 6(1)(a) – consent’ and ‘article 6(1)(b) – contract’ of the General Data Protection Regulation 2018.

6. How Do We Use Your Data?

  • All personal data is stored securely in accordance with the principles of the General Data Protection Regulation. For more details on security see section 7, below.
  • We use your data to provide the best possible service to you. This includes:
    • Providing and managing your access to Our Site;
    • Personalising and tailoring your experience on Our Site;
    • Supplying Our services to you;
    • Personalising and tailoring Our services for you;
    • Responding to communications from you;
    • Supplying you with email newsletters that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the unsubscribe option in the email;
    • In order to keep our site and your data safe and secure.
  • With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our 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 General Data Protection Regulation 2018, Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

7. How and Where Do We Store Your Data?

  • We only keep your 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.
  • If you leave a comment on Our Site, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.
  • Some or all of your data may be stored or transferred outside of the European Economic Area (“the 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. If We do store or transfer 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 EEA and under the Data Protection Act 1998. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.
  • We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our business.
  • Steps We take to secure and protect your data include:
    • Our Site is HTTPS/SSL encrypted
    • Our Site, accounts and devices are password protected
    • We use Wordfence security plugin to help protect Our Site from attempted hacks.
    • We keep our site and plug ins updated to minimise hacking risk
    • We commit to undertake regular data process audits
  • Notwithstanding the security measures that We take, it is important to remember that the transmission of data online may not be completely secure and that you are advised to take suitable precautions when transmitting data to us via the internet.

8. Do We Share Your Data?

  • We may sometimes contract with third parties to supply services to you on Our behalf. These may include 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 may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as affiliates and advertisers. Data will only be shared and used within the bounds of the law.
  • Visitor comments may be checked through an automated spam detection service.
  • In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

9. What Happens If Our Business Changes Hands?

  • We may expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
  • In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

10. How Can You Control Your Data?

  • When you submit information 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 the Mailing Preference Service (“the MPS”). This 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.

11. Your Right to Withhold Information

  • You may access Our Site without providing any data at all.
  • You may restrict your internet browser’s use of Cookies. For more information, see section 13 and Our Cookie Policy: https://nomipalony.com/cookie-policy/

12. How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). If the request is manifestly unfounded or excessive we may charge a “reasonable fee” for the administrative costs of complying with the request.

If you have have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

We may also charge a reasonable fee if you request further copies of your data following a request. The fee would be based on the administrative costs of providing further copies.

Please contact Us for more details at [email protected], or using the contact details below in section 13.

13. Cookies

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. For more details, please refer to Our Cookie Policy https://nomipalony.com/cookie-policy/

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

14. Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at [email protected] or by post at Unit 16808, PO Box 6945, London, W1A 6US. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above). Queries by email can be responded to quicker.

15. Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. 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. This notice was last reviewed in May 2018.