Privacy Policy

This privacy notice provides you with details of how we collect, store and process your personal data when you enquire about or purchase services from Joanna Lush Consulting.

Joanna Lush Consulting is the data controller, and we are responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice).

Our full details are:

• Full name of legal entity: Joanna Lush T/A Joanna Lush Consulting
• Email: consulting@joannalush.co.uk
• Postal address: Monte Grappa, Sea Road, Winchelsea Beach, East Sussex, TN36 4LB
• Telephone: 07714 257561 (also available on WhatsApp)

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at the address above.

Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process certain types of personal data about you as follows:

• Identity Data may include your first name, last name and title.
• Contact Data may include your billing address, email address and telephone numbers.
• Financial Data may include your bank account and payment details.
• Transaction Data may include details about payments between us and other details of purchases made by you.
• Profile Data may include purchases or orders, your communication preferences, feedback and survey responses.
• Usage Data may include information about how you use our website and services.
• Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.

Where we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver services to you). If you don't provide us with the requested data, we may have to cancel a service you have ordered, but if we do, we will notify you at that time.

Sensitive Data. We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

We collect data about you through a variety of different methods, including direct interactions: you may provide data by filling in forms or by communicating with us by post, phone, email, WhatsApp or otherwise, including when you:

• enquire about or purchase services from us;
• request resources or information be sent to you;
• give us feedback or leave a review.

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the contract between us.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you. You have the right to withdraw consent to marketing at any time by emailing us at consulting@joannalush.co.uk.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out.

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us to stop sending you marketing messages at any time by emailing us at consulting@joannalush.co.uk. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a service purchase or other business transactions.

Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal ground of processing. We may process your personal data without your knowledge or consent where this is required or permitted by law.

We may have to share your personal data with the parties set out below:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Third parties to whom we sell, transfer or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

We do not transfer your personal data outside the UK.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Withdraw consent.

You can see more about these rights at the ICO's guide to individual rights.

If you wish to exercise any of the rights set out above, please email us at consulting@joannalush.co.uk. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

If you have any questions about this privacy notice, please contact Joanna Lush, the Data Privacy Manager, on 07714 257561 or email consulting@joannalush.co.uk.