PRIVACY POLICY

This policy sets out the Edenway Property adherence principles and processes in relation privacy and GDPR regulatory requirements.

Edenway Property is registered with the Information Commissioners Office (ICO) as a tier 1 organisation and subscribes to UK GENERAL DATA PROTECTION REGULATION 2016/679 (GDPR) legal requirements.

1.   GDPR PRINCIPLES

The UK GDPR sets out seven key principles that CDO fully subscribes to:

1.1   Lawfulness, fairness and transparency

1.2   Purpose limitation

1.3   Data minimisation

1.4   Accuracy

1.5   Storage limitation

1.6   Integrity and confidentiality (security)

1.7   Accountability

2.   DATA PROTECTION PRINCIPLES

Edenway Property  complies with the data protection principles set out below. When processing personal data, it ensures that:

2.1  it is processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness,

      fairness and transparency’)

2.2 it is collected for specified, explicit and legitimate purposes and not further processed in a manner that is

      incompatible with those purposes (‘purpose limitation’)

2.3 it is adequate, relevant and limited to what is necessary in relation to the purposes for which it is

      processed (‘data minimisation’)

2.4 it is accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that

      personal data that is inaccurate, is erased or rectified without delay (‘accuracy’)

2.5 it is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is       

      processed (‘storage limitation’)

2.6 it is processed in a manner that ensures appropriate security of the personal data, including protection

      against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational   

      measures (‘integrity and confidentiality’)

2.7  it is responsible for the management of personal data in order to demonstrate compliance with the above

      principles  for example:

a)    adopting and implementing data protection policies;

b)   putting written contracts in place with clients

c)    maintaining documentation of our processing activities;

d)   implementing appropriate security measures;

e)    recording and reporting personal data breaches;

 f)    adhering to relevant codes of conduct and signing up to certification schemes.

3.   PROCESSING PERSONAL DATA

 Edenway Property  will:

3.1. Ensure that the legal basis for processing personal data is identified in advance and that all processing complies with the law

3.2. Not do anything with a clients data that they would not expect given the content of this policy and our privacy notice

3.3. Ensure that appropriate privacy notices are in place advising how and why their data is being processed, and, in particular, advising Clients of their         rights

3.4. Only collect and process the personal data that we need for purposes we have identified in advance

3.5. Ensure that, as far as possible, the personal data we hold is accurate and is kept up to date.

3.6. Only hold onto personal data for as long as it is needed  after which time CDO  will securely erase or delete the personal data.

3.7. Ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely.

4.    PERSONAL INFORMATION

“Personal Information” in this Privacy Policy, refers to information collected in order to provide the financial coaching service sessions, order Information and device information.

4.   PERSONAL INFORMATION (Coaching sessions)  

      We currently collect and process the following information:

4.1  Personal identifiers, contacts and characteristics (for example, name, address and contact details)

4.2 Email address information

4.3 Financial information (Only what you provide)

4.4 Family information (where applicable, such as number of dependants and married status)

5.    WHY WE HAVE IT

Any personal information we process is provided to us directly by you for one of the following reasons:

5.1    Contacting in event of cancellation or session change

5.2   Contacting for session reminders

5.3   Providing Pre and Post session deliverables

5.4   Assessing budgetary information

5.5   Where subscribed by clients agreement, providing financial coaching information and updates.

5.6   Information such as occupation and dependants to be able to provide more accurate consideration of expenses and guidance.

5.7   To process payments for sessions

5.8   Device Information that we collect helps us screen for potential risk and fraud (in particular your IP address) and more generally to improve and              optimise our site. 

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6.    PERSONAL ORDER INFORMATION

Order Information we collect is to fulfil any orders placed through the site. We use this Order Information to:

6.1    Process payments

6.2   Provide invoices

6.3   Provide order confirmations

6.4   Communicate with you.

6.5   Screen payment orders for potential risk or fraud.

6.6   Provide you with information or advertising relating to our products or services (when in line with the preferences you have shared with us).

7.    PERSONAL DEVICE INFORAMTION

7.1   When you visit the site, we automatically collect certain information about your device, including information about your web browser, IP address,            time zone and some of the cookies that are installed on your device.

7.2 Additionally, as you browse the site, we collect information about the individual web pages or products that you view, what websites or search                  terms referred you to the site and information about how you interact with the site. We refer to this automatically-collected information as “Device          Information”.

8.    ​COLLECTING DEVICE INFORMATION USING THE FOLLOWING TECHNOLOGIES:

8.1    Cookies are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about            cookies, and how to disable cookies, visit www.allaboutcookies.org.

8.2   Log files track actions occurring on the site and collect data including your IP address, browser type, internet service provider, referring/exit pages            and date/time stamps.

8.3   Web beacons, tags and pixels are electronic files used to record information about how you browse the site.

8.4   Additionally, when you make a payment through the site, we collect certain information from you including your name, billing address, shipping                address, payment information (including credit card numbers, email address, and phone number). We refer to this information as “Order                            Information”.

9.  ​​BEHAVIOURAL ADVERTISING

10.1  ​As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe                   may be of interest to you. 

10.2 For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page                                 at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

11. LAWFUL BASIS

     Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing information is:

     Contractual obligation:

     In order for us to fulfil our contractual obligation to you the client, we need to collect all relevant data to be able to provide you with the financial             coaching service you are paying us to help you with.   

12. STORAGE OF INFORMATION  

12.1   All information is securely stored. All electronic information is kept on separate external hard drives that are securely stored in security cabinets

        when not in use. All PC’s used for accessing personal data are password protected, have specialist security software and our routers are fully

        encrypted.

12.2  All hard copy information is permanently stored in secure lockable cabinets as per the ICO guidance. All keys are securely sorted in a key safe   

        when not in use.

12.3  We keep all information provided to us by you electronically or in hard copy (Letters or documents) for 6 months or where you exercise your data

        rights for erasure. We will then dispose your information by secure deletion from separate hard drives all information is stored on.

12.4  Hard copy information is thoroughly cross shredded and disposed of.

13.   CLIENT RIGHTS

Under the terms of the General Data Protection Regulation (GDPR) you have the following rights:

13.1   To be informed if your personal data is being used - An organisation must inform you if it is using your personal data.

13.2  To get copies of your data - You have the right to find out if an organisation is using or storing your personal data.

13.3  Your right to get your data corrected - You can challenge the accuracy of personal data held about you by an organisation.

13.4  To get your data deleted - You can ask an organisation to delete personal data that it holds about you.

13.5  To limit how organisations use your data - You can limit the way an organisation uses your personal data.

13.6  To data portability - You have the right to get your personal data from an organisation in a way that is accessible.

13.7  To object to the use of your data - You have the right to object to the processing or use of your personal data in some circumstances.

13.8  To make a data protection complaint - Tell an organisation if you're concerned about how they are using your data.

14. ENQUIRIES AND PROCESSING

14.1   Edenway Property  will facilitate any request from a data subject who wishes to exercise their right under data protection law as appropriate,

        always communicating in a clear, intelligible and easily accessible form and without undue delay. We have one month to respond to you.

14.2  For security reasons Edenway Property  may ask for proof of your identity before disclosing information about you, or to you, via email or over the 

        telephone.

14.3  To provide accurate complete Services Edenway Property  will need to collect information about your personal and financial circumstances where

        agreed and appropriate. Edenway Property  will only use personal information to deliver the Services.

14.4  You may request a copy of the Privacy Policy at any time by contacting admin@edenwayproperty.co.uk  or view it directly on our website

14.5  By using the Services and/or agreeing to these Terms, you accept Edenway Property practices regarding personal data and how it will be treated.

14.6  Edenway Property  will never share your data or information with any other third party except when it is directly required to provide the Services you

        have requested, as outlined above, or where you have given us explicit permission in advance to do so.

15.   COMPLAINTS

If you have any concerns about our use of your personal information, you can make a complaint to us at:

admin@edenwayproperty.co.uk

 You can also complain to the Information Commissioners Office (ICO) if you are unhappy with how we have used your data.

The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

 ICO website: https://www.ico.org.uk

NOTE: To better understand the complete suite of GDPR rights, processes and requirements, and to gain a more in-depth understanding of GDPR regulations, we have provided a link to the Information Commissioners Office (ICO) -  https://ico.org.uk