You will find below our full privacy statement regarding the way we collect and process your personal data, and your rights regarding this personal data.
We collect some personal data automatically, only for statistical purposes; otherwise, all of your personal data is given directly to us by you when you fill out our contact form or subscription form. We process this information only in compliance with the principles outlined in the General Data Protection Regulation (“GDPR”) (Regulation (EU) 2016/679 of April 27, 2016). We securely file this data via a reputable cloud storage company who are also compliant with the GDPR, and to third parties who take part in our services (for example, payment partners were applicable).
You may exercise several rights under the GDPR by contacting us, including the right to access your personal data (i.e. receive a copy of the information we have), the right to portability of your data (transfer your data to someone else), the right to rectify any mistake in your data, and, under certain conditions, the right to erase your data, and the right to object to or to restrict the processing of your personal data.
We remain available to answer any questions you may have regarding this Privacy Statement, which may be directed to [email protected], and invite you to read the full, binding statement below.
This document constitutes a binding agreement (hereafter the “Privacy Statement“) regarding the collection and processing of personal data by means of the website accessible via the domain name www.aschteconsultancy.com (hereafter the “Website“) between BeTheFirst Limited (hereafter “us” or “BTF“) and any visitor and/or user of the Website (hereafter “you” or the “User“). Throughout this Privacy Statement, the expression “personal data” refers to any information relating to an identified or identifiable natural person, as defined by the GDPR.
The Privacy Statement aims to inform you of the conditions under which your personal data is collected and processed by us and the rights that you have regarding this data.
In order to operate the Website and provide our services, we collect and process specific personal data, solely for the purposes detailed hereafter. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement.
1.1 We are committed to safeguarding the privacy of our website visitors; this policy sets out how we will treat your personal information.
2. Collecting personal information
2.1 When you visit our Website (regardless of whether you create a User profile), the following information about your visit is automatically collected by us, as it is sent by your browser when you access any webpage:
your computer’s or mobile device’s operating system;
the application or software that you used to access our Website;
the time you accessed our Website;
your browser type, language configuration, clicks, and page views;
the terminal with which you accessed our Website; and
the websites you visited before accessing our Website.
2.2 In accordance with Article 5(1)(e) of the GDPR, data should not be stored for longer than necessary, in relation to the purpose for which it is being processed. Seven years is the minimum period required to fulfil the purpose stated, as follows. The aim of this automatic collection and processing is to obtain visit statistics in order to improve our Website and your experience as a customer. In particular, we use IP addresses to analyze trends, administer the Website and gather broad demographic information for aggregate use.
2.3 This processing is lawful since it is necessary for the provision of our services in accordance with our Terms and Conditions, which you agreed to when visiting this Website
3. Using your personal information
3.1 Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
3.2 We may use your personal information to:
(a) administer our website and business;
(b) personalise our website for you;
(c) enable your use of the services available on our website;
(d) send you non-marketing commercial communications;
(e) send you email notifications that you have specifically requested;
(f) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(g) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(h) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(i) deal with enquiries and complaints made by or about you relating to our website;
(j) keep our website secure and prevent fraud;
(k) verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service);
3.3 If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant to us.
3.4 Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
3.5 We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
4. Disclosing personal information
4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
4.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
4.4 Except as provided in this policy, we will not provide your personal information to third parties.
5. Contact Form
5.1 You may use the contact form to send a message to BTF, register for events, or request information, including in order to exercise your rights as detailed in this Privacy Statement. When filling out the contact form, we may request the following information:
type of assistance required, and
your message (via a free-form field).
5.2 This information is required in order to process your message and answer your request, and is stored only as long as necessary in order to fully process your request.
5.3 When filling out the form and clicking the “submit” button, you expressly consent to this processing of your personal data, therefore making the processing lawful.
6. Retaining personal information
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
7. Security of your personal information
7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
7.3 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.4 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of changes to this policy.
9. Your rights
9.1 You have the following rights regarding your personal data that is collected and processed by us.
9.2 We will attempt to notify each recipient to whom your personal data has been disclosed (unless this proves impossible or involves disproportionate effort) when you notify us of a rectification or erasure of your personal data or a restriction of processing.
A. Right of access
You may request access to your personal data that we collect and process. Should you request such access, we will provide you with a copy of all your personal data in our possession as well as all legally required information, including:
the purposes of the processing;
the categories of personal data concerned;
the recipients to whom the personal data have been or will be disclosed;
the duration of storage of the personal data; and
further information on your rights regarding your personal data.
B. Right to data portability
You have the right to data portability of your personal data. This right differs from your right to access since it only relates to the personal data you provided us with (for example, automatically collected data is not included). This right allows you to receive this personal data in a structured, commonly used and machine-readable format in order for you to be able to transfer this personal data to another data controller or processor.
C. Right to rectification
You may, at any time, request that we rectify inaccurate or incomplete personal data concerning you, and we will proceed accordingly and promptly.
D. Right to erasure (‘right to be forgotten’)
You may request the erasure of your personal data provided that one of the following conditions apply:
your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
you withdraw your consent for the processing and there is no other legal ground for the processing (this only relates to the personal data collected via the contact form or for our newsletter purposes);
you exercise your right to object to the processing of your personal data, as detailed in section 6.5;
your personal data was unlawfully processed; or
your personal data has to be erased to comply with a legal obligation to which we are subject.
E. Right to object
Where your personal situation justifies it, you may object to the processing of your personal data by us when this processing is carried out in our legitimate interests.
You may also, at any time, object to the processing of your personal data by us when this processing is carried out for marketing purposes.
F. Right to restriction of processing
You may ask for the restriction of the processing of your personal data when one of the following applies:
where you contest the accuracy of your personal data, you can request the restriction of the processing of your personal data for the period required to verify your claim;
where the processing is unlawful, you may choose to request the restriction of the use of your personal data instead of requesting its erasure;
if we no longer need your personal data for the purpose of the processing, but you require this data for the establishment, exercise or defense of legal claims; or
where you objected to the processing of your personal data carried out in our legitimate interests, you may request the restriction of this processing while we investigate your claim.
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11.2 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.3 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.4 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
11.5 We use both session and persistent cookies on our website.
11.6 The cookies that we use on our website and the purposes for which they are used, are set out below:
(a) recognise a computer when a user visits the website
(b) track users as they navigate the website
(c) improve the website’s usability
(d) analyse the use of the website
(e) administer the website
(f) personalise the website for each user
(g) target advertisements which may be of particular interest to specific users
11.7 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking “Tools”, “Internet Options”, “Privacy” and then “Advanced”;
(b) in Firefox (version 24) you can block all cookies by clicking “Tools”, “Options”, “Privacy”, selecting “Use custom settings for history” from the drop-down menu, and unticking “Accept cookies from sites”; and
(c) in Chrome (version 29), you can block all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Content settings”, and then selecting “Block sites from setting any data” under the “Cookies” heading.
11.8 Blocking all cookies will have a negative impact upon the usability of many websites.
11.9 If you block cookies, you will not be able to use all the features on our website.
11.10 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at http://support.microsoft.com/kb/278835);
(b) in Firefox (version 24), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history”, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and
(c) in Chrome (version 29), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Delete cookies and other site and plug-in data” before clicking “Clear browsing data”.
11.11 Deleting cookies will have a negative impact on the usability of many websites.
12. Our details
12.1 This website is owned and operated by BeTheFirst Limited
12.2 We are registered in England and Wales under registration number 08074452, and our registered office is at 71-75 Shelton Street, London, England, WC2H 9JQ
12.3 Our principal place of business is at 71-75 Shelton Street, London, England, WC2H 9JQ
12.4 You can contact us by writing to the business address given above, by using our website contact form, by email to [email protected]