Privacy Policy

Last updated September 19, 2022

This privacy notice for EJ Gordon Associates Ltd ('Company', 'we', 'us', or 'our',), describes how and why we
might collect, store, use, and/or share ('process') your information when you use our services ('Services'),
such as when you:

Visit our website at https://www.ejgordonassociatesltd.co.uk, or any website of ours that links to this
privacy notice

Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and
choices. If you do not agree with our policies and practices, please do not use our Services. If you still have
any questions or concerns, please contact us at info@ejgordonassociatesltd.co.uk.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any
of these topics by clicking the link following each key point or by using our table of contents below to
find the section you are looking for. You can also click here to go directly to our table of contents.
What personal information do we process? When you visit, use, or navigate our Services, we may
process personal information depending on how you interact with EJ Gordon Associates Ltd and the
Services, the choices you make, and the products and features you use. 

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer
our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent. We process your information only when we
have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share
information in specific situations and with specific third parties.

How do we keep your information safe? We have organisational and technical processes and
procedures in place to protect your personal information. However, no electronic transmission over the
internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may
mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject
request form available here, or by contacting us. We will consider and act upon any request in accordance
with applicable data protection laws.
 

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining
information about us or our products and Services, when you participate in activities on the Services, or
otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context
of your interactions with us and the Services, the choices you make, and the products and features you use.
The personal information we collect may include the following:
 

• names
   
• email addresses
   
• contact preferences
   
• phone numbers

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us
of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with
you, for security and fraud prevention, and to comply with law. We may also process your information for
other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact
with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to
  provide you with the requested service.
   
• To respond to user inquiries/offer support to users. We may process your information to respond
  to your inquiries and solve any potential issues you might have with the requested service.
   
• To send administrative information to you. We may process your information to send you details
  about our products and services, changes to our terms and policies, and other similar information.
   
• To fulfil and manage your orders. We may process your information to fulfil and manage your
  orders, payments, returns, and exchanges made through the Services.
   
• To enable user-to-user communications. We may process your information if you choose to use
  any of our offerings that allow for communication with another user.
   
• To request feedback. We may process your information when necessary to request feedback and to
  contact you about your use of our Services.
   
• To protect our Services. We may process your information as part of our efforts to keep our
  Services safe and secure, including fraud monitoring and prevention.
   
• To save or protect an individual's vital interest. We may process your information when
  necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid
legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to
provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our
legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we
rely on in order to process your personal information. As such, we may rely on the following legal bases to
process your personal information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your
  personal information for a specific purpose. You can withdraw your consent at any time. Click here to
  learn more.
   
• Performance of a Contract. We may process your personal information when we believe it is
  necessary to fulfil our contractual obligations to you, including providing our Services or at your
  request prior to entering into a contract with you.
   
• Legitimate Interests. We may process your information when we believe it is reasonably necessary
  to achieve our legitimate business interests and those interests do not outweigh your interests and
  fundamental rights and freedoms. For example, we may process your personal information for some of
  the purposes described in order to:
  
  
  • Diagnose problems and/or prevent fraudulent activities
     
  • Understand how our users use our products and services so we can improve user experience.
     
• Legal Obligations. We may process your information where we believe it is necessary for compliance
  with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency,
  exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are
  involved.
   
• Vital Interests. We may process your information where we believe it is necessary to protect your vital
  interests or the vital interests of a third party, such as situations involving potential threats to the safety
  of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e. express consent) to use your
personal information for a specific purpose, or in situations where your permission can be inferred (i.e.
implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information
without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
   
• For investigations and fraud detection and prevention
   
• For business transactions provided certain conditions are met
   
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an
  insurance claim
   
• For identifying injured, ill, or deceased persons and communicating with next of kin
   
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
   
• If it is reasonable to expect collection and use with consent would compromise the availability or the
  accuracy of the information and the collection is reasonable for purposes related to investigating a
  breach of an agreement or a contravention of the laws of Canada or a province
   
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to
  the production of records
   
• If it was produced by an individual in the course of their employment, business, or profession and the
  collection is consistent with the purposes for which the information was produced
   
• If the collection is solely for journalistic, artistic, or literary purposes
   
• If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following
third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during
  negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our
  business to another company.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy
notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this
privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or
other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either
delete or anonymise such information, or, if this is not possible (for example, because your personal
information has been stored in backup archives), then we will securely store your personal information and
isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical
security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed
to protect the security of any personal information we process. However, despite our safeguards and efforts
to secure your information, no electronic transmission over the Internet or information storage technology can
be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other
unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or
modify your information. Although we will do our best to protect your personal information, transmission of
personal information to and from our Services is at your own risk. You should only access the Services within
a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you
represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such
minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of
age has been collected, we will deactivate the account and take reasonable measures to promptly delete
such data from our records. If you become aware of any data we may have collected from children under age
18, please contact us at info@ejgordonassociatesltd.co.uk.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada,
you have rights that allow you greater access to and control over your personal information. You may review,
change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection
laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to
request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if
applicable, to data portability. In certain circumstances, you may also have the right to object to the
processing of your personal information. 

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information,
you also have the right to complain to your local data protection supervisory authority. You can find their
contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which
may be express and/or implied consent depending on the applicable law, you have the right to withdraw your
consent at any time. You can withdraw your consent at any time by contacting us at info@ejgordonassociatesltd.co.uk.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when
applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful
processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at
info@ejgordonassociatesltd.co.uk.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track
('DNT') feature or setting you can activate to signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this stage no uniform technology standard for
recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT
browser signals or any other mechanism that automatically communicates your choice not to be tracked
online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about
that practice in a revised version of this privacy notice.

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated
'Revised' date and the updated version will be effective as soon as it is accessible. If we make material
changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or
by directly sending you a notification. We encourage you to review this privacy notice frequently to be
informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at
info@ejgordonassociatesltd.co.uk or by post to:

EJ Gordon Associates Ltd
61 Bridge Street,

Kington

HR5 3DJ

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT
FROM YOU?

You have the right to request access to the personal information we collect from you, change that information,
or delete it. To request to review, update, or delete your personal information, please submit a request form
by clicking here.