Privacy Policy 

Northstar Wisdom (NSW) is committed to protecting your personal data in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. This policy details the types of personal data we collect, how we use it, the lawful basis for processing, and your rights as a data subject. We ensure transparency, security, and respect for your privacy at every stage of data processing, including data collected via our hosting provider, IONOS.

1. About Us (The Data Controller)

Northstar Wisdom (NSW) is the Data Controller responsible for your personal data collected through this website.

  • Organisation: Northstar Wisdom (NSW)
  • Location: United Kingdom
  • Contact: info@northstar-wisdom.com

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data, which we have grouped as follows:

Category of Data

Examples of Data Collected

Identity Data

Name, Company Name.

Contact Data

Email address, Telephone number (phone number), Postal address.

Technical Data

Internet Protocol (IP) address (often anonymised), browser type and version, operating system, time zone setting and location.

Usage Data

Information about how you use our website, pages viewed, time spent on site, and navigation paths.

Marketing Data

Your preferences in receiving marketing from us and our third parties.

We do not collect any Special Categories of Personal Data (such as race, religion, health, etc.).

3. How Your Personal Data is Collected

We use different methods to collect data from and about you, including:

  • Direct Interactions: You may give us your Identity and Contact Data by filling in forms, subscribing to services, or corresponding with us by post, phone, email, or otherwise.
  • Automated Technologies or Interactions (Hosting and Analytics): As you interact with our website, Technical and Usage Data is collected automatically.

4. Third-Party Data Processing (IONOS Hosting)

This website is hosted by IONOS SE (or 'IONOS'), who acts as a processor of certain Technical and Usage Data.

Data Collected by IONOS:

IONOS collects technical data to ensure the security and proper functionality of the website, and for statistical evaluation via IONOS SiteAnalytics, which is a non-cookie-based analytics tool. The data collected typically includes:

  • The website you visited before ours (Referrer URL).
  • The specific website pages or files requested.
  • Browser type and version, and operating system used.
  • Time of website access.
  • The IP address, which is typically anonymised immediately after transfer and processed without personal reference to determine the location of access.

NSW has a Data Processing Agreement (DPA) in place with IONOS, guaranteeing that your data is processed only in accordance with our instructions and in compliance with the UK GDPR.

5. Cookies and Tracking Technologies

This website uses various technologies, including cookies, to enhance your experience, analyse site usage, and support our marketing efforts.

  • What are Cookies? Cookies are small text files stored on your device that help us recognise you and your preferences.
  • Types of Cookies Used:
    • Strictly Necessary Cookies: Essential for the website's operation (e.g., security, load-balancing).
    • Analytical/Performance Cookies (First-Party): Used to count visitor numbers and see how visitors navigate the site (may include some IONOS-related tracking where cookies are used for statistical analysis, separate from SiteAnalytics).
    • Functionality Cookies: Used to recognise you when you return to our website to personalise content.
    • Targeting/Marketing Cookies (Third-Party): Deposited and managed by partners for marketing purposes, such as showing you relevant advertisements.
  • Other Tracking Technologies: We may also employ Tags (sections of code for basic tracking) and Pixels (small graphics for limited data transmission, e.g., purchase conversion tracking) to monitor activity.

Your Consent: We will request your explicit consent for all non-essential cookies and tracking technologies before they are set on your device. You can manage your preferences at any time via our cookie banner or settings.

6. Purposes and Lawful Basis for Processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances and based on the following lawful bases:

Purpose for Data Processing

Type of Data Used

Lawful Basis for Processing

To register you as a new customer/user.

Identity, Contact.

Performance of a contract with you.

To process and fulfil your service requests.

Identity, Contact, Financial.

Performance of a contract with you.

To manage our relationship with you and notify you of changes to our terms or policies.

Identity, Contact.

Necessary to comply with a legal obligation; Necessary for our legitimate interests (keeping our records updated).

To administer and protect our business and website (including troubleshooting, data analysis, security, and hosting).

Identity, Technical, Usage.

Necessary for our legitimate interests (for running our business, security, and network provision).

To deliver relevant website content and advertisements to you and measure the effectiveness of the advertising.

Identity, Contact, Usage, Marketing, Technical.

Necessary for our legitimate interests (to study customer use, develop services, and inform our marketing strategy) or Consent (where required for cookies).

To use data collected by IONOS for statistical evaluation.

Technical, Usage (anonymised IP).

Necessary for our legitimate interests (monitoring and improving site performance and security).

7. Data Security and Retention

Data Security: We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorised way, altered, or disclosed. This includes physical, electronic, and managerial procedures. We also limit access to your personal data to those employees, agents, and third parties who have a business need to know.

Data Retention: 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.

  • For example, we generally keep customer contact data for a period of six years after they cease being a customer, for tax and legal compliance purposes.
  • Technical data collected by IONOS is typically stored for a maximum of eight weeks.

8. International Transfers

We do not generally transfer your personal data outside of the UK. However, if any of our third-party service providers (e.g., specific analytical or marketing partners) are based outside the UK, we ensure a similar degree of protection is afforded by ensuring:

  • The country has been deemed to provide an adequate level of protection for personal data by the UK government; or
  • We use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

9. Your Legal Rights as a Data Subject

Under data protection law, you have rights regarding your personal data. These rights include:

  • The Right to Access: The right to request copies of your personal data.
  • The Right to Rectification: The right to ask us to correct information you think is inaccurate or incomplete.
  • The Right to Erasure (The right to be forgotten): The right to ask us to erase your personal data in certain circumstances.
  • The Right to Restrict Processing: The right to ask us to restrict the processing of your personal data in certain circumstances.
  • The Right to Object to Processing: The right to object to the processing of your personal data in certain circumstances.
  • The Right to Data Portability: The right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.

If you make a request, we have one month to respond to you. There is no charge for exercising these rights.

10. How to Complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details in Section 1. You also have the right to lodge a complaint with the supervisory authority, which in the UK is the Information Commissioner’s Office (ICO).

  • ICO Contact Details: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
  • ICO Website: www.ico.org.uk

 

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