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Privacy Policy

Introduction:

This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

 

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain.

 

This website is not intended for children and The Conte Club does not knowingly collect data relating to children unless required for proper performance by The Conte Club. It is important that you read this privacy notice together with any other privacy notice you may be provided by The Conte Club on specific occasions when collecting or processing personal data. This privacy notice supplements the other notices and is not intended to override them.

 

Controller

 

The Conte Club is the controller and responsible for your personal data. The Conte Club has appointed a data protection officer (DPO) who is responsible for questions regarding this Privacy Policy. If you have any questions about this privacy policy, please contact the DPO using the contact details below.

 

Contact details

 

The Conte Club Ltd

 Attention of the CEO,

40 Bloomsbury Way,

Lower Ground Floor,

London WC1A 2SE

Telephone number: +44 3333 444 233

Email: admin@theconteclub.com

 

Complaints

 

In the event that you wish to make a complaint about how your personal data is being processed by The Conte Club or its partners, you have the right to complain to The Conte Club’s CEO. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

The Conte Club would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Data Protection Regulator

Information Commissioners Office

Telephone +44 (0) 303 123 1113 or email: registration@ico.org.uk

 

Personal Data

 

This document aims to give you information on how The Conte Club collects and processes your personal data. Personal date or personal information means any information which identifies an individual. The Conte Club may collect, use, store and transfer different kinds of personal data which The Conte Club have grouped together as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
● Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

The Conte Club may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

The Conte Club does not collect any Special Categories of Personal Data about you (this 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 unless specifically required in order to perform the instructions you give to The Conte Club for quotes with Operators or this information is provided to The Conte Club by you). Nor do we collect any information about criminal convictions and offences.

 

Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. The Conte Club may from time to time use such information to identify its visitors. The Conte Club will collect statistics about the behaviour of visitors to its website.

 

The Conte Club uses the information collected from you to provide quotations, make telephone contact and to email you marketing information which The Conte Club believes may be of interest to you and/or your business. In you making initial contact you consent to The Conte Club maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services.

 

The Conte Club’s website uses cookies, which is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Theconteclub.com uses cookies to help The Conte Club identify and track visitors and their website access preferences. The Conte Club website visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using The Conte Club’s website.

 

Any information The Conte Club holds about you and/or your business, encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.

 

The Conte Club will only collect the information needed so that it can provide you with marketing and consulting services, this agency does not sell or broker your data. The Conte Club will not purchase any information from a third-party list broker for any reason.

If you fail to provide personal data

Where The Conte Club needs to collect personal data by law, or under the terms of a contract in place with you and The Conte Club, and you fail to provide that data when requested, The Conte Club may not be able to perform the contract already in place or trying to enter into with you (for example, to provide you with goods or services). In this case, The Conte Club may have to cancel a product or service with you but you will be notified by The Conte Club if this is the case at the time.

Legal basis for processing any personal data

To meet The Conte Club‘s contractual obligations to clients and to also respond to marketing enquiries.

 

Legitimate interests pursued by The Conte Club and/or its clients.

 

To promote the marketing and consulting services offered by The Conte Club and/or to market the services and/or products offered by The Conte Club’s existing clients.

​Purposes for which we will use your personal data

The Conte Club will only use your personal data when the law allows us to. Most commonly, The Conte Club will use your personal data in the following circumstances:

  • Where The Conte Club needs to perform the contract The Conte Club is about to enter into or have entered into with you.

  • Where it is necessary for The Conte Club legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where The Conte Club needs to comply with a legal or regulatory obligation.

A description of all the ways The Conte Club plans to use your personal data are set out below along with the legal basis and also identified what The Conte Club legitimate interests are where appropriate. Note that The Conte Club may process your personal data for more than one lawful ground depending on the specific purpose for the data use. Please contact The Conte Club if you need details about the specific legal ground relied upon on the processing of your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

Performance of a contract with you

(a) Identity
(b) Contact

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)

To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications

To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

(a) Identity
(b) Contact
(c) Technical

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

(a) Technical
(b) Usage

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Necessary for our legitimate interests (to develop our products/services and grow our business)

(a) Identity
(b) Contact

(c) Technical
(d) Usage
(e) Profile
(f) Marketing and
Communications

To make suggestions and recommendations to you about goods or services that may be of interest to you

Consent

Through agreeing to this privacy notice you are consenting to The Conte Club processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing admin@theconteclub.com or writing to us, using the contact details.

Change of Purpose

The Conte Club will only use your personal data for the purposes for which it was collected for, unless The Conte Club reasonably considers that The Conte Club needs to use it for another reason and that reason is compatible with the original purpose. If you wish to get any explanation as to how the processing for the new purpose is compatible with the original purpose, please contact The Conte Club.

 

If The Conte Club needs to use your personal data for an unrelated purpose, The Conte Club will notify you and will explain the legal basis which allows The Conte Club to do so. Please note The Conte Club may process your personal data without your knowledge or consent, in compliance with the rules within this data policy, where this is required or permitted by law.

Disclosure

The Conte Club may need to share your personal data with third party law firms or other professional advisors with whom it is necessary to share your personal data in order to provide you with the services The Conte Club has contracted with you for. This may involve transferring your data outside the European Economic Area (EEA).

 

Whenever The Conte Club transfers your personal data out of the EEA, The Conte Club ensures a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • The Conte Club will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

  • Where The Conte Club uses certain service providers, The Conte Club may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

  • Where The Conte Club uses providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact The Conte Club if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

The Conte Club do not broker or pass on information gained from your engagement with the agency without your consent. However, The Conte Club may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety The Conte Club, its clients and/or the wider community.

Data Retention 

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

To determine the appropriate retention period for personal data, The Conte Club will 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 The Conte Club processes your personal data and whether The Conte Club can achieve those purposes through other means, and the applicable legal requirements.

By law The Conte Club must keep basic information about The Conte Club customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances The Conte Club 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.

Data security

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. We will only process your personal data on your instructions and they are subject to a duty of confidentiality.

 

The Conte Club has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where The Conte Club are legally required to do so.

To access what personal data is held, identification will be required

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. We will only process your personal data on your instructions and they are subject to a duty of confidentiality. The Conte Club has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where The Conte Club are legally required to do so.

All requests should be made to admin@theconteclub.com or writing to us at the address further below.

Your Legal Rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data The Conte Club holds about you and to check that The Conte Club are lawfully processing it.

Request correction of the personal data that The Conte Club holds about you. This enables you to have any incomplete or inaccurate data The Conte Club holds about you corrected, though The Conte Club may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask The Conte Club to delete or remove personal data where there is no good reason for The Conte Club continuing to process it. You also have the right to ask The Conte Club to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where The Conte Club may have processed your information unlawfully or where The Conte Club are required to erase your personal data to comply with local law. Note, however, that The Conte Club may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where The Conte Club are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where The Conte Club are processing your personal data for direct marketing purposes. In some cases, The Conte Club may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask The Conte Club to suspend the processing of your personal data in the following scenarios: (a) if you want The Conte Club to establish the data’s accuracy; (b) where The Conte Clubs use of the data is unlawful but you do not want The Conte Clubs to erase it; (c) where you need The Conte Club to hold the data even if The Conte Club no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to The Conte Clubs use of your data but The Conte Club needs to verify whether The Conte Club has overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. The Conte Club will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for The Conte Club to use or where The Conte Club used the information to perform a contract with you.

Withdraw consent at any time where The Conte Club are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, The Conte Club may not be able to provide certain products or services to you. The Conte Club will advise you if this is the case at the time you withdraw your consent.

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