Privacy Policy
1. INTRODUCTION
1.1. This privacy policy (“Policy”) relates to the website at https://courageousteamoffi.wixsite.com/courageousteam , any subdomain or any such related website and/or mobile application for such website (together the “Website”).
1.2. You should read this Policy carefully as it contains important information about how we will use your Information (as defined below in clause 4.1). In certain circumstances (see below) you will be required to indicate your consent to the processing of your Information as set out in this Policy when you first submit such Information to or through the Website. For further information about consent see clause 7 below.
1.3. We may update this Policy from time to time in accordance with clause 16 below. This Policy was last updated on 12.04.2021.
2. ABOUT US
2.1. The terms “COURAGEOUS” or “us” or “we” refer to COURAGEOUS Team Ltd, the owner of the Website. We are a company registered in UK and Wales under company number XXXXXX and “you” refers to the individual accessing and/or submitting Information to the Website.
2.2. We, as the Data Controller, can be contacted via our representative, Owen YIP, via email on owenyip.yk@gmail.com.
3. DATA PROTECTION
3.1. References in this Policy to:
3.1.1. “Privacy and Data Protection Requirements” means: the Data Protection Act 1998 (until repealed) (“DPA”), the Data Protection Directive (95/46/EC) (until repealed) and, from 25 May 2018, the General Data Protection Regulation 2016/679 (“GDPR”) or any equivalent provision which may replace the GDPR following the formal political separation of the United Kingdom from the European Union; the Regulation of Investigatory Powers Act 2000; the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699); the Electronic Communications Data Protection Directive (2002/58/EC); the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003); and all applicable laws and regulations which may be in force from time to time relating to the processing of Personal Data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner or any other supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction; and
3.1.2. “Personal Data”, “Data Controller” and “Data Processor” and “processing” shall have the meanings given to them in the DPA or, from 25 May 2018, the GDPR.
3.2. For the purposes of applicable Privacy and Data Protection Requirements, we (COURAGEOUS Team Ltd) are a Data Controller and therefore we are responsible for, and control the processing of, your Personal Data in accordance with applicable Privacy and Data Protection Requirements. “Personal Data” has a legal definition but, in brief, it refers to information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. Such information must be protected in accordance with applicable Privacy and Data Protection Requirements.
4. INFORMATION WE MAY COLLECT ABOUT YOU
4.1. When you use the Website and/or when you otherwise deal with us we may collect the following information about you (“Information”):
4.1.1. personal information including first and last name, date of birth, photograph and/or likeness;
4.1.2. contact information including current residential address, primary email address and/or primary phone number;
4.1.3. billing information including payment card details, and billing address;
4.1.4. technical information including IP address, operating system, browser type and related information regarding the device you used to visit the Website, the length of your visit and your interactions with the Website;
4.1.5. information obtained through our correspondence and monitoring in accordance with clause 4.2 below; and
4.1.6. details of any enquiries made by you through the Website, together with details relating to subsequent correspondence (if applicable).
4.2. We may monitor your use of the Website through ‘cookies’ and similar tracking technologies. We may also monitor traffic, location and other data and information about users of the Website. Such data and information, to the extent that you are individually identifiable from it, shall constitute Information as defined above. However, some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. See clause 15 below for further information on our use of cookies.
4.3. Occasionally we may receive information about you from other sources, for example any delivery companies, cloud service providers, e-commerce software providers you connect with through the Website, or from any third-party websites and applications that integrate or communicate with the Website in relation to you. If so, we will add this information to the Information we already hold about you in order to help us carry out the activities listed below.
5. HOW LONG WE KEEP YOUR INFORMATION
5.1. Subject to clause 5.2, we will keep your Data only for the purposes set out in the table below for:
5.1.1. where the legal basis for the processing is that it is necessary for the performance of the contract between us, we will keep the Information for the period between your registration with our Website for six years or until consent is withdrawn or you delete your account (whichever is sooner); or
5.1.2. where the processing is subject to your continued consent to the processing of your data for that specific purpose, we will keep your data for six years or until you withdraw your consent, whichever is sooner.
5.2. If required, we will be entitled to hold Information for longer periods in order to comply with our legal or regulatory obligations.
6. LEGAL BASIS FOR PROCESSING YOU INFORMATION
6.1. From 26 September 2018, under applicable Privacy and Data Protection Requirements we may only process your Information if we have a “legal basis” (i.e. a legally permitted reason) for doing so. For the purposes of this Policy, our legal basis for processing your Information is set out below.
Why we will process your information:
a. to operate, administer, maintain, provide, analyse, improve and update you about your order as part of our services and our Website
b. to investigate and address any comments, queries or complaints made by you regarding our services or the Website, and any similar or related comments, queries or complaints from other users
c. to ensure that content from the Website is presented in the most effective manner for you and for your device
d. to allow you to participate in interactive features of the Website, including inputting information and providing feedback
e. to conduct research, statistical analysis and behavioural analysis (including anonymising data for these purposes)
f. to provide insights based on aggregated, anonymous data collected through the research and analysis
g. to contact you for marketing purposes
h. to disclose your information to selected third parties as permitted by this Policy (see clause 9 below);
i. where required by (but not limited to) any request or order from law enforcement agencies and/or HMRC in connection with any investigation to help prevent unlawful activity.
The legal basis which applies to each of the above:
a. this is necessary for the performance of the contract between us and Information is processed to enable us provide services to our users.
b. this is necessary for the performance of the contract between us and Information is processed to enable us provide services to our users.
c. this is necessary for the performance of the contract between us and Information is processed to enable us provide services to our users.
d. this is necessary for the performance of the contract between us and Information is processed to enable us provide services to our users.
e. this is necessary for the performance of the contract between us and Information is processed to enable us provide services to our users.
f. this is necessary for the performance of the contract between us and Information is processed to enable us provide services to our users.
g. we send out marketing communications based on our legitimate interests of providing goods and keeping people informed about the services we offer. The method of communication may vary as set out as follows: we may send you information via post or, if you are dealing with us on behalf of a limited company or LLP, to your corporate email address; we will only contact you via your personal email address if: (i) you have given your consent (see 'Marketing and opting out' in clause 8 below); or (ii) you have previously bought goods and services from us and we are contacting you to let you know about similar goods and services that we offer (see ‘Marketing and opting out' in clause 8 below). You have the right at any time to let us know that you no longer wish to receive marketing communications from us.
h. this processing is subject to your continued consent to the processing of your data for that specific purpose (see 'Marketing and opting out' in clause 8 below), except where we have to disclose your information to comply with our legal obligations, including obligations relating to the protection of Personal Data.
i. to comply with our legal obligations, including obligations relating to the protection of Personal Data.
7. YOUR CONSENT TO PROCESSING
7.1. As noted above, you will be required to give consent to certain processing activities before we can process your Information as set out in this Policy. Where applicable, we will seek this consent from you when you first submit Information to or through the Website.
7.2. If you have previously given consent you may freely withdraw such consent at any time. You can do this through your account on the Website or by notifying us in writing (see clause 19 below).
7.3. If you withdraw your consent, and if we do not have another legal basis for processing your information (see the table in clause 6 above), then we will stop processing your Information. If we do have another legal basis for processing your information then we may continue to do so subject to your legal rights (for which see clause 13 below).
7.4. Please note that if we need to process your Information in order to operate the Website and/or provide our services, and you object or do not consent to us processing your Information, the Website and/or those services may not be available to you.
8. MARKETING AND OPTING OUT
8.1. Where you are dealing with us on behalf of a limited company or LLP, for business purposes, then we may contact you by email to your corporate email address about similar or related products that we offer. If you prefer not to receive any direct marketing communications from us, or you no longer wish to receive them, you can opt out at any time (see below).
8.2. Where you have previously ordered products or services from us we may contact you by email about similar or related products, services, promotions and special offers that may be of interest to you. We will inform you (during the sale process) if we intend to use your data for such purposes and give you the opportunity to opt-out of receiving such information from us. In addition, and if you have given permission, we may also contact you by email about our other products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your data) and seek your permission if we intend to use your data for such additional marketing purposes. If you prefer not to receive any direct marketing communications from us, or you no longer wish to receive them, you can opt out at any time (see below).
8.3. If you have given permission, we may contact you by mail, telephone and email to provide information about products, services, promotions, special offers and other information we think may be of interest to you. We will inform you (before collecting your data) if we intend to use your data for such purposes. If you would rather not receive such marketing information from us, or you no longer wish to receive it, you can opt out at any time (see below).
8.4. If you have given permission, we may share your personal data with carefully selected third party organisations and business partners and they may contact you directly (unless you have asked them not to do so) by email about products, services, promotions and special offers that may be of interest to you. We will inform you (before collecting your data) and seek your permission if we intend to disclose your data to third parties for such purposes. If you prefer not to receive direct marketing communications from our business partners, or you no longer wish to receive them, you can opt out at any time (see below).
8.5. You have the right at any time to ask us, or any third party, to stop processing your information for direct marketing purposes. If you wish to exercise this right, you should contact us by sending an email to courageousteamoffice.com, or contact the relevant third party using their given contact details, giving us or them enough information to identify you and deal with your request. Alternatively you can follow the unsubscribe instructions in any emails you receive from us or them regarding marketing.
9. DISCLOSURE OF YOUR INFORMATION
9.1. We may disclose your Information (including Personal Data):
9.1.1. to other companies within our group of companies (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006);
9.1.2. to our business partners, service providers or third-party contractors to enable them to undertake services for us and/or on our behalf (and we will ensure they have appropriate measures in place to protect your Information);
9.1.3. to any prospective buyer or seller (and their represenatives) in the event that we sell or buy any business or assets;
9.1.4. if we are under a duty to disclose or share Personal Data in order to comply with any legal obligation, including (but not limited to) any request or order from law enforcement agencies and/or HMRC in connection with any investigation to help prevent unlawful activity; and
9.1.5. to other third parties if you have specifically consented to us doing so under clause 8.3.
9.2. We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Website. In such circumstances we do not disclose any information which can identify you personally.
9.3. If our whole business is sold or integrated with another business your Information may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
10. KEEPING YOUR INFORMATION SECURE
10.1. We will use technical and organisational measures in accordance with good industry practice to safeguard your information, including the use of data encryption.
10.2. While we will use all reasonable efforts to safeguard your Information, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Information that is transferred from you or to you via the internet.
11. INFORMATION ABOUT OTHER INDIVIDUALS
If you give us information on behalf of a third party, you confirm that the third party has appointed you to act on his/her/their behalf and has agreed that you can: give consent on his/her/their behalf to the processing of his/her/their Information; receive on his/her/their behalf any data protection notices; and give consent to the transfer of his/her/their Information abroad (if applicable).
12. CONTACT US
We welcome your feedback and questions on this Policy. If you wish to contact us, please email us at courageousoffice@gmail.com