We (Denise Oyston and Sharon Newey, joint commercial owners of this website) understand that your privacy is important to you and that you care about how your personal data is used and shared online.
We both respect and value the privacy of everyone who visits this website, Superfastrecruitment.co.uk and we will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.
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 – usually the training membership area for Superfast Circle members;
“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;
“cookie Law”: Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
“personal data”: Means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data you give us via our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our”: Means Denise Oyston and Sharon Newey, trading as Fast Track Your Sales Ltd (Superfast Recruitment is one brand of our organisation), whose registered address is 341 Lytham Road Blackpool.
Information About Us
2.1 Our Site is owned and operated by Denise Oyston and Sharon Newey, trading as Fast Track Your Sales Ltd (Superfast Recruitment is one division of our organisation) whose registered address is 341 Lytham Rd Blackpool Lancashire FY4 1DS, United Kingdom
2.2 Our Data Protection Officer is Sharon Newey and can be contacted by email at Sharon@superfastrecruitment.co.uk or by telephone at 01524 920 700.
What Does This Policy Cover?
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:
4.1.1 The right to be informed about our collection and use of your personal data;
4.1.2 The right of access to the personal data we hold about you (see section 12);
4.1.3 The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you (we only hold your personal data for a limited time, as explained in section 6 but if you would like us to delete it sooner, please contact us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision-making and profiling.
4.2 If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14, and we will do our best to solve the problem for you. If we cannot help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
What Data Do We Collect?
5.2 contact information such as email addresses and telephone numbers;
5.3 demographic information such as country, postcode, preferences, and interests;
5.4 financial information such as credit/debit card numbers (NB we do not collect this information directly, but if you make a purchase, it will be collected by our payment providers – Stripe, Paypal and GOCARDLESS;
5.5 IP address;
5.6 web browser type and version;
5.7 operating system;
5.8 a list of URLs starting with a referring site, your activity on our Site, and the site you exit to;
How Do We Use Your Data?
6.1 All personal data is processed and stored securely for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the GDPR at all times. For more details on security, see section 7 below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g. by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:
6.2.6 Replying to emails from you;
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt out at any time by clicking the unsubscribe link at the bottom of each and every email we send );
6.2.8 Market research to understand the views and preferences of our website visitors and email subscribers;
6.2.9 Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience;
6.3 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, text message, facebook messenger, LinkedIn messenger (or other online messaging services) or post with information, news and offers on our products or services. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to us using your personal data at any time and to request that we delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will, therefore, be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 Your name and email address that you use to subscribe to our regular emails and any preferences you supply and related information on links clicked and pages visited will be retained as long as you remain an email subscriber. If you unsubscribe from our emails your details will be deleted within 3 months as part of regular housekeeping (with the exception noted below);
6.5.2 Your details as above, plus any purchase information about products you have bought from us will be retained as long as you have access to those products and our Superfast Circle training Site. If you cancel or return products (and do not have access to any other products) your details will be deleted as above within 3 months as part of regular housekeeping, with the exception of any information needed to comply with legal requirements (e.g. tax purposes).
How and Where Do We Store Your Data?
7.1 We only keep your personal 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.
7.2 Some or all of your data may be stored 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 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 UK and under the GDPR including:
7.2.1 Ensuring that all systems we use to store data are GDPR compliant or have the equivalent protection (e.g. certification to the EU-U.S. Privacy Shield Framework).
7.3 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our Site.
7.4 Steps we take to secure and protect your data include:
7.4.1 All data is held in password-protected areas with the password being known only to our data protection officer unless you are a service client and then this password would be shared with the employees that are working on your account only.
7.4.2 All devices used to access your data are also password/PIN/biometric protected.
Do We Share Your Data?
8.1 Subject to sections 8.2-8.5, we will not share any of your data with any third parties for any purposes.
8.2 We may sometimes contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, services, search engine facilities, 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.
8.3 We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 We may sometimes use third-party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal 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 UK and under the GDPR including:
8.4.1 Infusionsoft: Infusionsoft stores your name, email address and other preference related data for email marketing. Infusionsoft stores your data in the US and have committed to being GDPR compliant by May 25th, 2018.
8.4.2 Stripe: for processing credit card transactions. Stripe transactions are processed by Stripe Ireland which is EU based. Some data is transferred and processed by Stripe in the US and this data is protected by the EU-U.S. and Swiss-U.S. Privacy Shield Framework (details here: https://stripe.com/privacy-shield-policy).
8.4.4 Thrivecart: Thrivecart is the shopping cart we use. It stores your name, email address and details of what you have purchased. For some products, it also stores your mailing address. It does not store your financial information – that is handled by Stripe/Paypal. Thrivecart have committed to being GDPR compliant by May 25th, 2018.
8.4.6 Dropbox: the data stored on personal computers used to run the business is mirrored to Dropbox and this may occasionally include personal data when it is downloaded from the other systems used in the business. Dropbox has committed to being GDPR compliant by May 25th 2018.
8.4.7 Kajabi: Kajabi stores your name, email address and other preference related data for access to our training programmes. Kajabi stores your data in the US and have committed to being GDPR compliant by May 25th 2018.
8.5 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
What Happens If our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via our Site, you may be given options to restrict our use of your data. In particular, we aim to give you control 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 and if you are a part of our membership program Superfast Circle, by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These 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 receive.
Your Right to Withhold Information
11.1 You may access certain areas of our Site without providing any data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data. In particular, to access the private members’ section of the site you will need to register and buy one of our products.
How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by us (where such data is held). Under the GDPR, no fee is payable, and we will provide any and all information in response to your request free of charge. Please contact us for more details at firstname.lastname@example.org or using the contact details below in section 14.
13.2 By using our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on our Site for advertising (e.g. Google, Facebook, LinkedIn or similar services which we may choose to use over time), website analytics (e.g. Google Analytics, and similar analytics services which we may choose to use over time). For more details, please refer to section 6, above, and to section 13.6 below. These cookies are needed to support the successful operation of our business. If you do not wish for them to be placed, please do not use the Site.
13.3 Details of our site’s specific cookies are as follows: Google Analytics and Google Console, Google Adwords, Facebook and LinkedIn.
13.4 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.5 You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
13.6 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. Terms of Business
Payments for our programmes are made in advance. Our Superfast Circle programme is a 12-month commitment.
Beyond this, should you choose to continue, we then require 1 month’s notice of cancellation.
If a staged payment has been agreed this remains payable on the due date. The resources we provide cannot be used with companies you work for. The exception is a brand you own.