Privacy Policy
Serrano 99 Management Consulting Limited and it’s brand “positive & mindful leader” (“We”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting serrano99.com, positivemindfulleader.com, pml-summit.com or pml-institute.com you are accepting and consenting to the practices described in this policy.
The data controller is SERRANO 99 MANAGEMENT CONSULTING LIMITED, 30 Finsbury Square, London, EC2A 1AG.
Compliancewith The Principles of GDPR
(a) Data must be processed lawfully, fairly and in a transparent manner in relation to individuals.
Serrano 99 Management Consulting has a legitimate interest (see Annex A) to process personal data relating to decision makers and budget holders in medium-to-large organisations. The data is gathered from publicly available sources and directly from the companies concerned.
(b) Data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
Data is collected solely for the purpose of compiling a database of business contacts to be used by Serrano 99 Management Consulting for business-to-business information services and marketing.
(c) Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
The data collected is limited to names of senior managers, their job titles, company addresses, company landline telephone numbers and corporate email addresses.
(d) Data must be accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
Serrano 99 Management Consulting checks all information by telephone three times a year to ensure that it is kept accurate and up-to-date.
(e) Data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals.
If we learn of a person to leave their role, their name and contact details are deleted from the database. However the information may still be used for suppression purposes i.e. to ensure that it cannot be added to the database again.
(f) Data must be 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.
Data is only provided to Serrano 99 Management Consulting and its brand ‘positive & mindful leader’ offering legitimate business services that are relevant to the professional role of the data subject. Serrano 99 Management Consulting operates a rigorous data security environment.
(g) Individuals have the right to see, correct, restrict access to or remove their personal information.
For subject access requests, contact hello@serrano99.com.
(h) Complaints. Individuals have a right to complain to the Information Commissioner if they believe that there is a problem with the way their data is being used.
Follow this link to contact the ICO.
This Website
- Privacy Protection
We recognise the need to protect the personal information that might be gathered from our customers, potential customers and visitors to our website. We will only use the information that we collect about you lawfully, in accordance with GDPR. You can access and browse this website without disclosing personal information.
- Data collection
We collect information about you for two reasons: firstly, to process your order and secondly, to provide you with information about our services. All information is gathered and used solely as part of the service we offer you and is processed and stored in accordance with the requirements of GDPR.
We collect personally identifiable information about you if you register to receive details of special offers on our site; if you purchase any of our products; if you contact us with comments or specific requests or if you provide a business card or other details to any of our staff.
The elements of your data that we collect may include:
- forename and surname
- title
- company name
- company address, phone and/or fax number
- email address
- where relevant credit card information (e.g. type, number, expiry date)
- other information specific to the nature of our interaction
We also collect anonymous information which is not unique to you such as:
- IP address
- Browser Type
- Access times
- Referring URL
- User access and control of your data
You may request a copy of the personal information we have about you and you may correct it if you wish, using the contact details shown above. If at any time you wish to withdraw your consent to our use of your data please contact hello@serrano99.com.
- Data use
We use your data for the following purposes: to process orders and enquiries, to provide you with information about our products and services, to inform you about developments in the positive & mindful leader world that we believe may be of interest to you.
- Cookies
We use cookies to help make it easier for you to access our website. Cookies are pieces of information that a website transfers to your computer’s hard disk so that the website can remember who you are. Most websites use cookies. Cookies cannot be used by themselves to identify you. Cookies are also used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. By using our website you agree that we can place these types of cookies on your computer. You may prevent us from storing a cookie on your computer by setting your browser so that it will not accept cookies. However, this will prevent you from placing orders on the site.
- Data disclosure
The data we gather about you from our website will never be sold on to a third party. In certain circumstances, we may need to disclose your data to appropriate third parties if you breach the terms and conditions of use of this website or our services to you. We may also access or disclose your data if required to do so by law or an authorised governmental body.
- Security
The security of your data is important to us. We have implemented technology and security policies, rules and measures designed to protect the personal data under our control, both on- and off-line, from unauthorised access, improper use, alteration, unlawful or accidental destruction, and accidental loss. Off-line, all of our “personal user data” is restricted in our offices. Only employees of Serrano 99 Management Consulting are granted access to such information. Please remember, however, that no data transmission over the internet can be absolutely guaranteed to be totally secure. While we strive to protect your data as best we can, we cannot ensure or warrant the security of any information which you send to us, or which we store.
- Other websites
This website contains links to other sites. When you choose to visit those sites, we cannot assume responsibility for any other site’s content or information handling practices. We encourage you to review each site’s privacy policy prior to entering into transactions with the third party-linked site.
- Privacy support
If you have any questions or comments about privacy, please contact us.
ANNEX A
Legitimate Interests Assessment
To comply with GDPR, Serrano 99 Management Consulting has carried out a Legitimate Interests Assessment which is documented below
Purpose of Processing
Serrano 99 Management Consulting has a legitimate interest to process personal data relating to decision makers and budget holders in medium-to-large organisations. The data is gathered from publicly available sources and directly from the companies concerned.
Lawful Business Objective
The processing is necessary in order to supply Serrano 99 Management Consulting with data for business-to-business information and marketing purposes; a lawful business objective specifically identified by the Privacy and Electronic Communications Regulations 2003 (PECR). Recital 47 of the GDPR identifies direct marketing as a legitimate use of personal information.
Reasonable Expectation
The data subjects are senior business people with decision making and budgetary responsibilities and can reasonably expect to be contacted with information and marketing material relating to their professional roles.
Adequate, Relevant & Limited
The data collected is limited to names of senior managers, their job titles, company addresses, company landline telephone numbers and corporate email addresses. If a person notifies us of leaving their role, their name and contact details are deleted from the database.
Opt Out
If a data subject requests that their data is removed from the database, it is suppressed so that it cannot be accessed or added again at a later date.
Valuable Service
In offering the latest information on positive and mindful leadership application, Serrano 99 Management Consulting provides a valuable service to senior managers. In the absence of Serrano 99 Management Consulting and similar high-quality service providers, corporate decision makers would have to rely on limited and out-of-date information for their business needs, which would have a detrimental effect on the success of their businesses and the wider economy.
Serrano 99 Management Consulting has updated its privacy policy to show that we are relying on legitimate interests to process data.
What is Legitimate Interests?
Legitimate Interests is one of the six lawful bases for processing personal data under the GDPR (General Data Protection Regulation). You must have a lawful basis in order to process personal data in line with the ‘lawfulness, fairness and transparency’ principle.
Legitimate interests might be your own interests, or the interests of the third party receiving the data, or a combination of the two.
Latest guidance from the Information Commissioner says that legitimate interests may be the most appropriate basis when:
“the processing is not required by law but is of a clear benefit to you or others; there’s a limited privacy impact on the individual; the individual should reasonably expect you to use their data in that way; and you cannot, or do not want to, give the individual full upfront control (i.e. consent) or bother them with disruptive consent requests when they are unlikely to object to the processing.”
You can read the Information Commissioner’s guidance on legitimate interests in full on the ICO website
Comments are closed.