This Policy applies as between You and Vida Consultancy Ltd (t/a Maclynn), the owner and provider of this Website and Services. This Policy applies to Our use of any and all Data collected by Us in relation to Your use of Our Website and Services.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Services”||means services provided by Vida Consultancy Ltd, including but not limited to Private Membership, Open Membership and coaching, provided to You under a separate agreement|
|“Cookie”||means a small text file placed on Your computer or device by Our Site when You visit certain parts of Our Site and/or when You use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;|
|“UK and EU Cookie Law”||means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;|
|“Personal Data”||means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (GDPR)|
|“You”||Means You as the user of this Website or a Maclynn Member.|
|“Website”||means the website that You are currently using (thevidaconsultancy.com or maclynninternational.us) and any sub-domains of this site unless expressly excluded by their own terms and conditions.|
|“We/Us/Our”||means Maclynn ,registered as Vida Consultancy Ltd a limited company registered in England under company number 07671741|
2. Information About Us
2.1 Vida Consultancy Ltd, a Company registered in England & Wales under Company number 07671741, is the data controller and responsible for Your Personal Data.
Our Website is owned and operated by Vida Consultancy Ltd
2.2 Our VAT number is 151067731
3. What Does This Policy Cover?
Our Website and Services are not intended for children and our Services are restricted to users who are 18 years of age or older. We do not knowingly collect data relating to children.
4. Your Rights
4.1 As a data subject, You have rights under the GDPR, which this Policy and Our use of Personal Data have been designed to uphold, including:
4.1.1 The right to be informed about Our collection and use of Personal Data;
4.1.2 The right to request access to the Personal Data We hold about You (see section 12);
4.1.3 The right to rectification if any Personal Data We hold about You is inaccurate or incomplete (if you believe this to be the case, please contact Us using the details in section 14);
4.1.4 The right to request erasure of the Personal Data We hold about You. (We only hold Your Personal Data for a limited time, as explained in section 6 but if You would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict or prevent the processing of Your Personal Data;
4.1.6 The right to request transfer of Your Personal Data;
4.1.7 The right to object to Us using Your Personal Data for particular purposes;
4.1.8 The right to withdraw Your consent to Us Processing Your Personal Data; and
4.1.9 Rights with respect to automated decision making and profiling.
4.2 If You have any cause for complaint about Our use of Your Personal Data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for You. If We are unable to help, You also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about Your rights, please contact the Information Commissioner’s Office or the Supervisory Authority in Your jurisdiction if you live outside the UK.
5. What Data Do We Collect?
5.1.1 Identity data including name; marital status, title; date of birth; gender
5.1.2 contact data such as billing address, email addresses and telephone numbers;
5.1.3 demographic information such as post code, preferences and interests;
5.1.4 information relevant to Our Service delivery such as preferences in a partner, lifestyle, values, career, profession, job title and other personal information disclosed to us;
5.1.5 Financial data including bank account and payment card details;
5.1.6 Transaction Data including details about payments from You and other details of services you have purchased from Us;
5.1.7 Usage data including information about how You use Our Website and Services;
5.1.8 Marketing and Communications data including Your preferences in receiving marketing from Us and Our third parties and Your communication preferences;
5.1.9 Technical data including Your IP address (automatically collected), web browser type and version (automatically collected), operating system (automatically collected); and a list of URLs starting with a referring site, Your activity on Our Website (automatically collected).
5.2 Some of the information You choose to provide Us may be considered “special” or “sensitive” in certain jurisdictions, for example Your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, You consent to Our processing of that information.
5.3 Where We need to collect personal data under the terms of a contract We have with You, and You fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with You to provide you with Our Services. In this case, We may have to cancel the Service You have with Us but We will notify You if this is the case at the time.
6. How Do We Use Your Data?
6.1 All Personal Data is processed and stored securely for no longer than is necessary, taking into account the reason(s) for which it was collected. We will comply with Our obligations and safeguard Your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of Your Personal Data will always have at least one lawful basis: because it is necessary for Our performance of a contract with You, because You have consented to Our use of Your Personal Data (e.g. by subscribing to emails), or because it is in Our legitimate interests and Your interests and fundamental rights do not override those interests. Specifically, We may use Your Personal Data for the following purposes:
6.2.1 to deliver Our Services to You;
6.2.2 to manage Our relationship with You;
6.2.3 to manage payments, and collect and recover money owed to Us;
6.2.4 improvement of Our products / Services;
6.2.5 to administer and protect Our business and Website;
6.2.6 to make suggestions and recommendations to You about goods or services that may be of interest to you e.g. by email or phone;
6.2.7 to contact You for market research purposes e.g. by email or telephone;
6.2.8 to use data analytics to improve Our Website, products/Services, marketing, customer relationships and experiences;
6.3 With Your permission and/or where permitted by law, We may also use Your Personal Data for marketing purposes which may include contacting You by email AND/OR telephone AND/OR text message with information, news and offers on Our Services. We will not, however, send You any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect Your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003. You have the right to withdraw Your consent to marketing at any time by contacting Us.
6.4 We will only use Your Personal Data for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If We need to use Your Personal Data for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so. Please note that We may process Your Personal Data without Your knowledge or consent where this is required or permitted by law.
6.5 We will only retain Your Personal Data for as long as reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain Your Personal Data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to Our relationship with You.
6.6 To determine the appropriate retention period for Personal Data, We 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 We process Your Personal Data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We typically retain Your Personal Data for the periods set out below, subject to any exceptional circumstances or to comply with laws or regulations that require a specific retention period:
6.6.1 In the case of Maclynn Members only:
i) Personal Data provided by You for the matchmaking process: 7 years after the termination of Your membership, or no longer than 7 years of inactivity
ii) Financial data: provided You have made all payments due to Us, as soon as possible after termination of Your membership;
iii) Transaction data and details of Your contract with Us may be retained for up to 7 years.
6.6.2 With respect to Technical, Usage and Marketing & Communications data, for 2 years, unless a longer retention period is required by law.
7. How and Where Do We Store Your Data?
7.1 Some or all of Your data will be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using or visiting Our Site and/or submitting information to Us, or by entering into an agreement with Us to use Our Services. If We do store data outside the EEA, We will take all reasonable steps to ensure that Your data is treated as safely and securely as it would be within the UK, and in accordance with the GDPR.
7.2 Data security is very important to Us, and 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, consultants and other third parties who have a business need to know. They will only process Your Personal Data on Our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify You and any applicable regulator of a breach where we are legally required to do so.
8. Do We Share Your Personal Data?
8.1 We may share Your Personal Data with our business partners in order to deliver our Services. This includes any affiliated company including Maclynn International NY LLC, Maclynn International NJ LLC, and Maclynn International LA LLC registered in the USA plus any future business entities formed in the United States. Maclynn International is an independently owned, wholly separate company.
8.2 We may sometimes contract with third parties to supply services to You on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing, as well as delivery of our Services. In some cases, the third parties may require access to some or all of Your Personal Data. Where any of Your Personal Data is required for such a purpose, We require all third parties to respect the security of Your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use Your Personal Data for their own purposes and only permit them to process Your Personal Data for specified purposes and in accordance with our instructions.
8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify You. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any Personal Data outside the EEA, We will take all reasonable steps to ensure that Your data is treated as safely and securely as it would be within the UK and under the GDPR.
8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include Your Personal Data, for example, where We are involved in legal proceedings, or where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of Your data is to be transferred in such a manner, You will be contacted in advance and informed of the changes. When contacted You will not, however, be given the choice to have Your data deleted or withheld from the new owner or data controller.
10. How Can You Control Your Data?
10.1 When You submit Personal Data, You may be given options to restrict Our use of Your data. In particular, We aim to give You strong controls on Our use of Your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which You may do by unsubscribing using the links provided in Our emails or at the point of providing Your details or by contacting us at a later date).
11. Your Right to Withhold Information
11.1 You may access certain areas of Our Site without providing any data at all.
11.2 You may choose to withhold any information, providing it is not in breach of the terms of the agreement relating to Your Service.
12. How Can You Access Your Data?
12.1 You have the right to ask for a copy of any of Your Personal Data held by Us (where such data is held). You will not have to pay a fee to access Your Personal Data. However, We may charge a reasonable fee if Your request is clearly unfounded, repetitive or excessive. Alternatively, We could refuse to comply with Your request in these circumstances.
12.2 We may need to request specific information from You to help us confirm Your identity and ensure Your right to access Your Personal. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact You to ask You for further information in relation to Your request to speed up our response.
12.3 We try to respond to all legitimate requests within one month. Occasionally it could take Us longer than a month if Your request is particularly complex or You have made a number of requests. In this case, We will notify you and keep You updated. Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in section 14.
13.1 A cookie is a small file of letters and numbers that we store on Your browser or the hard drive of Your computer if you agree. Cookies contain information that is transferred to Your computer’s hard drive.
13.2 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.3 Before Cookies are placed on Your computer or device, You will be shown a pop-up requesting Your consent to set those Cookies. By giving Your consent to the placing of Cookies You are enabling Us to provide the best possible experience and service to You. You may, if You wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
13.4 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”.
13.5. Your consent will not be sought to place these Cookies, but it is still important that You are aware of them. You may still block these Cookies by changing Your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Site may not work properly if You do so. We have taken great care to ensure that Your privacy is not at risk by allowing them.
13.5 Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to Your privacy or Your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for You.
13.6 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
13.7 In addition to the controls that We provide, You can choose to enable or disable Cookies in Your internet browser. Most internet browsers also enable You to choose whether You wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in Your internet browser or the documentation that came with Your device.
13.8 You can choose to delete Cookies on Your computer or device at any time, however You may lose any information that enables You to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
13.9 It is recommended that You keep Your internet browser and operating system up-to-date and that You consult the help and guidance provided by the developer of Your internet browser and manufacturer of Your computer or device if You are unsure about adjusting Your privacy settings.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if Your personal data changes during Your relationship with us.