Organisation: Ability Consultancy (NW) Ltd (company no. 11871599, Great Britain). Registered office: 15 Braintree Avenue, Penwortham, Preston PR1 9UN.

Introduction

This privacy notice explains how we collect and process information that you provide to us or that we collect about you. It covers information that could identify you (“personal information”) and information that could not. In this notice, “process” means collect, store, transfer, use or otherwise act on information. It also explains your privacy rights and how the law protects you.

We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not only about legal compliance; it reflects our respect for you and your information. We undertake to preserve the confidentiality of all information you provide to us and ask that you reciprocate.

Our policy complies with the Data Protection Act 2018 and incorporates the EU General Data Protection Regulation (GDPR). For more on your rights and our obligations, please see knowyourprivacyrights.org.

Except as set out in this notice, we do not share, sell, or disclose to a third party any information collected through our website.

1. Data we process

We may collect, use, store and transfer different kinds of personal data about you, grouped as follows:

• Your identity: first name, last name, title, date of birth and other identifiers.
• Your contact information: billing and delivery address, email address, telephone numbers and other details provided for communication or meetings.
• Your financial data: bank account and payment card details.
• Transaction data: details about payments to and from you and information about products and services you have purchased from us.
• Technical data: IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

We may aggregate anonymous data (statistical or demographic) for any purpose. Aggregated data may be derived from your personal data but is not considered personal information in law because it does not reveal your identity. If we combine or connect aggregated data with your personal information so that it can identify you, we treat the combined data as personal information.

2. If you do not provide personal information we need

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you at the time.

The bases on which we process information about you

The law requires us to determine under which of the six defined bases we process different categories of your personal information and to notify you of the basis for each category. If a basis is no longer relevant, we will stop processing your data. If the basis changes, we will notify you of the change and any new basis, if required by law.

3. Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. To carry out our obligations under that contract, we must process the information you give us. Some of this information may be personal information.

We may use it to:

• verify your identity for security purposes;
• sell products to you;
• provide you with our services;
• provide suggestions and advice on products, services and how to obtain the most from using our website.

We process this information because there is a contract between us, or because you have asked us to use the information before we enter into a legal contract. We continue to process it until the contract ends or is terminated by either party under its terms.

4. Information we process with your consent

When there is no contractual relationship between us, such as when you browse our website or ask us for information about our business, products, or services, you may provide your consent to process personal information.

Wherever possible, we obtain your explicit consent—for example, by asking you to agree to our use of cookies.

If you have given us explicit permission, we may pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by emailing info@ability-consultancy.co.uk. If you do so, you may not be able to use our website or our services further.

5. Information we process for the purposes of legitimate interests

We may process information on the basis of a legitimate interest, either to you or to us, after carefully considering:

• whether the same objective could be achieved through other means;
• whether processing (or not processing) might cause you harm; and
• whether you would expect us to process your data and, in the round, consider it reasonable to do so.

For example, we may process data on this basis for:

• record-keeping for the proper and necessary administration of our organisation;
• responding to unsolicited communications from you;
• protecting and asserting the legal rights of any party;
• insuring against or obtaining professional advice required to manage organisational risk; and
• protecting your interests where we believe we have a duty to do so.

6. Information we process because we have a legal obligation

We may need to process your information to comply with a statutory obligation. For example, we may be required to give information to legal authorities if requested or authorised (e.g., by search warrant or court order). This may include your personal information.

Specific uses of information you provide to us

7. Complaints regarding content on our website

We attempt to moderate user-generated content but cannot always do so immediately. If you complain about any content, we shall investigate. If we consider your complaint justified or required by law, we shall remove the content while we investigate. If we think your complaint is vexatious or without basis, we shall not correspond with you about it.

8. Information relating to your method of payment

Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it. At the point of payment, you are transferred to a secure page on the website of PayPal, Stripe, or another reputable payment service provider. That page may be branded to look like our site, but it is not controlled by us.

9. Communicating with us

When you contact us by telephone, through our website or by email, we collect the data you have given to us to reply with the information you need. We record your request and our reply to improve efficiency. We keep personally identifiable information associated with your message (such as your name and email address) so we can provide a high-quality service.

10. Complaining

When we receive a complaint, we record all the information you provide and use it to resolve your complaint. If your complaint reasonably requires us to contact another person, we may share some information from your complaint with them. We do so as infrequently as possible and at our sole discretion. We may also compile statistics from complaints to assess our service level, but not in a way that could identify you or anyone else.

Use of information we collect through automated systems when you visit our website

11. Cookies

Cookies are small text files placed on your device by your web browser. They allow information gathered on one web page to be stored for use on another, enabling a personalised experience and providing the website owner with usage statistics.

Some cookies last for a defined period, such as one day or until you close your browser; others last indefinitely. Your browser should allow you to delete any you choose and to prevent or limit their use.

Our website uses cookies placed by software on our servers and by third-party software whose services we use. When you first visit, we ask whether you wish us to use cookies. If you decline, we shall not use them for your visit except to record your choice.

If you choose not to use cookies or prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies to:

• track how you use our website;
• record whether you have seen specific messages on our website;
• keep you signed in to our website;
• record your answers to surveys and questionnaires while you complete them; and
• record the conversation thread during a live chat with our support team.

Disclosure and sharing of your information

12. Information we obtain from third parties

Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data indirectly comprised of your personal information from third parties whose services we use. No such information is personally identifiable to you.

13. Data may be processed outside the European Union

Our websites are hosted in the UK. We may also use outsourced services in countries outside the European Union in other aspects of our business. Accordingly, data obtained within the UK or any other country could be processed outside the European Union.

For example, some of the software our website uses may have been developed in the United States of America or in Australia.

We use the following safeguards for data transferred outside the EU:

• the processor is within the same corporate group as our organisation and abides by the same binding corporate rules regarding data processing;
• our contracts with data processors include data protection clauses with transfer provisions approved by a supervisory authority in the UK;
• we comply with a code of conduct approved by a supervisory authority in the UK;
• we are certified under an approved certification mechanism as provided for in the Act; and
• both our organisation and the processor are public authorities between whom there is a legally binding agreement or administrative arrangement approved by a supervisory authority in the EU relating to protection of your information.

Control over your own information

14. Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

15. Access to your personal information

You may review or update personally identifiable information that we hold about you by signing in to your account on our website. To obtain a copy of any information not provided on our website, please contact us to make that request. After receiving the request, we will tell you when we expect to provide the information and whether any fee is required.

16. Removal of your information

If you wish us to remove personally identifiable information from our website, please contact us. This may limit the service we can provide to you.

17. Verification of your information

When we receive any request to access, edit or delete personally identifiable information, we shall first take reasonable steps to verify your identity before taking any action. This safeguards your information.

Other matters

18. Use of site by children

We do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with consent from a parent or guardian.

19. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Look for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

20. How you can complain

If you are not happy with our privacy policy or have a complaint, please tell us. If a dispute is not settled, we hope you will agree to attempt to resolve it by engaging in good faith with us in mediation or arbitration.

If you are dissatisfied with how we process your personal information, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO): ico.org.uk/make-a-complaint. We would, however, appreciate the opportunity to address your concerns before you approach the ICO.

21. Retention period for personal data

Except as otherwise mentioned in this notice, we keep your personal information only for as long as required:

• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by tax authorities; and
• to support a claim or defence in court.

22. Compliance with the law

Our privacy policy has been compiled to comply with the law of every country or jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we would like to hear from you. However, ultimately it is your choice whether you use our website.

23. Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any questions regarding our privacy policy, please contact us.