Privacy
Policy
This
Privacy Policy contains important information about the personal information we collect about you, what we do with your information, and who your information
might be shared with. We will not
disclose your information to anyone other than as set out in this Privacy
Policy and any applicable terms and conditions.
Topics:
· Who
we are
· What
personal information do we collect?
· How
do we collect your personal information?
· How
will we use your personal information?
· How
do we store your personal information?
· Marketing
· What
are your personal information protection rights?
· In
the case of a breach
· Complaint
resolution
· Third
party advertising
· Links
to third party websites
· Children
· What
are cookies?
· How
do we use cookies?
· What
types of cookies do we use?
· How
to manage your cookies?
· Privacy
policies of other websites
· Changes
to our privacy policies
· Registration
with the ICO
· How
to contact us
· How
to contact the appropriate authorities
Who We Are
Same Page Mediation (SP) is the business name operated by Alicia M. Page as a sole trader. SP provides mediation and conflict resolution training (together
referred to as “Services”) in-person in the UK and online. In the course of these offerings we must
collect, use and are responsible for certain personal information about you.
When we do so we are regulated under the General Data Protection Regulation
which applies across the European Union and the United Kingdom, and we are
responsible as ‘controller’ of that personal information for the purposes of
those laws.
What personal information do we collect?
Personal information about you could include but is
not limited to:
· your
name
· address
(personal and/or employment)
· contact
details including phone number and email
· financial
details related to payment for services
· sensitive
personal information
How do we collect your personal
information?
· You
directly provide SP with most of the personal information we collect through:
· Placing
an order for or registering for Services
· Sharing
potentially sensitive personal information related to the provision of services. These could include, but are not limited to:
synopses of conflict situations, litigation histories, relationship histories, training,
and educational experience, provided by you or about you by a third party
· Voluntarily
completing a customer survey or feedback and evaluation through email, via the
website or in-person
· Use
or view our website via your browser’s cookies.
· Our
Company does not purchase any information from third parties.
· SP may obtain information about you from a third party in relation to their Services provided by SP. Your rights remain the same in relation to this information and SP will treat the information as confidential and retain only with legitimate legal bases.
How will we use your personal information?
· SP
collects information so that we can process your order, manage your account, arrange,
and provide Services, collect payment, and meet compliance obligations
· SP
will email you with marketing products only with your permission
· Sensitive
personal information is retained only as long as SP is providing Services and
if so, will be destroyed immediately following the conclusion of Services
· SP
will never sell your personal information to a third party
· SP
will not share your information with a third party unless otherwise required by
law
· SP
processes information about clients, trainees and other professionals in a way
that is necessary to manage the agreed relationship with that individual.
· SP
will never ask you to share any personal information outside the context of
Services provision or marketing preferences.
Legal bases for processing your personal
information
The legal bases we may
rely on include:
· consent:
where you have given us clear consent for us to process your personal
information for a specific purpose, consent can be withdrawn at any time.
· contract:
where our use of your personal information is necessary for a contract we have
with you, or because you have asked us to take specific steps before entering
into a contract.
· legal
obligation: where our use of your personal information is necessary for us to
comply with the law (not including contractual obligations).
· public
task: where our use of your personal information is necessary for us to perform
a task in the public interest or for our official functions, and the task or
function has a clear basis in law.
· legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).
|
Personal data
type: |
Source: |
Legal basis for
processing: |
|
Name and contact
information (phone, email, address of business or work) |
Provided by you
through email/ phone/ website contact with SP; or a third party with relation
to interests in their dealings with SP |
Consent: if
provided by you. Legitimate
interest: for processing, arranging, and dealing with services, complaints, marketing,
or other purposes necessary to SP service provision. Contract: to
fulfill services and/or to obtain payment for services rendered |
|
Financial details
including bank account and sorting numbers, credit card details |
Provided by you
through email/ phone/ website contact with SP |
Consent: if
provided by you for purposes of payment for services rendered. Legitimate
interest: for processing/ collection of payment Contract: to
fulfill services and/or to obtain payment for services rendered |
|
Sensitive personal
information: may involve a variety of information related to ongoing
mediation cases or relevant to training |
Provided by you
through email/ phone/ website contact with SP; or a third party with relation
to interests in their dealings with SP |
Consent: if
provided by you for the purpose of providing Services. Legitimate
interest: for providing confidential mediation services or information
related to provision of appropriate training services; |
|
Any or all of
above information |
Provided by you
or through a third party |
Public task and
legal obligation: SP will only reveal personal information if required to by
law in pursuit of a public task or legal obligation |
How do we store your personal information?
· Your
personal information is stored in a manner only accessible by SP personnel.
· Personal
information is kept for record keeping, account management, and compliance for
as long as is reasonably necessary for the provision of Services, Marketing,
and fulfillment of legal obligations.
· You
may ask to have your information changed or removed from our systems at any
time and we will comply with the exception of any legal obligations to the
contrary.
· Sensitive
personal information obtained during the Provision of services will be
destroyed after services are rendered excepting Agreements to Mediate retained for
the purposes of record keeping and to track potential conflicts of interest.
Marketing
· Where
you have consented to us using your personal information to contact you for
marketing purposes you may opt out at any time.
· Where
you have given express written consent for us to use your personal information
in our marketing materials, you may opt out at any time.
What are your personal information
protection rights?
· You
have the right to request SP provide copies of your personal data. We may charge a small fee for this service.
· You
have the right to request that SP correct any information you believe is
inaccurate or complete information you believe is incomplete.
· You
have the right to request that SP erase your personal data, under certain
conditions
· You
have the right to request that SP restrict the processing of your personal data
under certain conditions.
· You
have the right to request that SP transfer the data that we have collected to
another organization, or directly to you, under certain conditions.
· You
have the right to object to certain types of processing such as direct
marketing,
· You
have the right to object to automated decision making concerning your personal
data, where automatic decisions may be made based upon such personal data.
· Where you are using our website, we may link to other websites owned and operated by third parties. These other third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third-party websites, please consult their privacy policies as appropriate.
In the case of a breach
All clients of which we
have personal information will be contacted within a reasonable appropriate
timeframe from discovery of the breach and informed of the nature and extent of
the breach and its possible implications.
Complaint resolution
· Complaints
can be made utilizing the methods described in the official SP Complaint Policy
published on the website,
· Personal information related to complaints will only be kept for the purposes of handling any complaint processing and resolution purposes.
Third party advertising
SP does not participate in third
party advertising.
Links to third party websites
Any links to third party
websites are as a result of unpaid affiliations.
Children
Our website and services
are not intended for use by children, and we do not knowingly collect or use
personal information relating to children.
What are cookies?
Cookies
are text files placed on your computer to collect standard Internet log
information and visitor behavior information.
When you visit our website, we may collect information from you
automatically through cookies or similar technology.
How do we use cookies?
SP uses cookies to improve your experience on our
website including:
· Understanding
how you use our website
· Keeping
you signed in
What types of cookies do we use?
Strictly necessary cookies
are essential to making a website work properly including maintaining user
session and preventing security threats.
They do not collect or store any personal information.
Performance cookies collect
anonymous information about users to assess the performance of the website such
as the number of unique visitors to the site, the pages they view most and the
source of their visit.
Functional cookies
allow non-essential functionalities on the website like embedding content like
videos and sharing content on social media.
Preference cookies
allow us to store your setting and browsing preferences for a better website
viewing experience.
How to manage your cookies?
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool "Real Cookie Banner". Details on how "Real Cookie Banner" works can be found at <a href="https://devowl.io/rcb/data-processing/" rel="noreferrer" target="_blank">https://devowl.io/rcb/data-processing/</a>.
The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
Privacy policies of other websites
On occasion SP website may contain links to other
websites. Our privacy policy applies
only to our website, so if you click on a link to another website, you should
read their privacy policy.
Changes to our privacy policies
SP keeps its privacy policy under regular review and
places any updates on this web page.
This privacy policy was last updated on 21 September 2023.
Registration with the Information
Commissioner’s Office (ICO)
ICO registration number ZB599263 for Same Page Mediation
Alicia Page is the registered person with the ICO.
How to contact us
If you have any questions about SP’s privacy policy,
the data we hold on to, or would like to exercise one of your data protection
rights, please do not hesitate to contact us.
· Email:
alicia@samepagemediation.co.uk
· Phone: +44 7388148626
· Same Page Mediation
6 Middleton Road, Sudbury, Suffolk CO10 2DB
How to contact the appropriate authorities
Should
you wish to report a complaint or if you feel that SP has not addressed your
concern in a satisfactory manner, you may contact the Information
Commissioner’s Office (ICO).
· Phone:
0303 123 1113
· Website address:
https://ico.org.uk/,ake-a-complaint
· Postal
Address: Information Commissioner’s
Office, Wycliffe
House, Water Lane, Wilmslow, Cheshire SK9 5AF