If you need to know how we comply with GDPR and how we look after your data - whether it's in our practice or via the website or newsletter here's how it works:

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Privacy Policy Notice

The policy: This privacy policy notice is for GWA Ltd and includes the website; https://gedwelch.wixsite.com/thenudge and governs the privacy of those who use it. The purpose of this policy is to explain to you how we control, process, handle and protect your personal information when we work with you or whilst you are browsing or using this website, including your rights under current laws and regulations. If you do not agree to the following policy you may wish to  contact us, unsubscribe from our mailings or avoid our website.

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Policy key definitions:

• "I", "our", "us", or "we" refer to the business, GWA.

• "you", "the user" refer to the person(s) using this website.

• GDPR means General Data Protection Act.

• PECR means Privacy & Electronic Communications Regulation.

• ICO means Information Commissioner's Office.

• Cookies mean small files stored on a users computer or device.

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Processing of your personal data

Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.

• Lawful basis: Consent
  The reason we use this basis: if you have signed up for our mailing list you have given us specific consent to contact you.
  We process your information in the following ways: when you sign up for our mailing list we use a third party service to store your data. We ensure they comply with existing data regulations and will continue to review this.
  Data retention period: We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.
  Sharing your information: We do not share your information with third parties.

• Lawful basis: Contract
  The reason we use this basis: as part of our service to our clients it is necessary to hold and process certain data and we do not require your individual consent to do this, as employees of a client who has engaged us to a task it is necessary for us to do this to perform our role.
  We process your information in the following ways: 

  • we hold your contact data using a GDPR compliant email system.

  • We take notes from meetings, conversations and workshops using both paper and electronic systems (like Dropbox or google). Any manual notes are stored securely. Only employees have access to these notes and only if relevant to a task. Employees are contractually obliged to be compliant with GDPR and treat all information as confidential.

  • We occasionally ask a client to conduct a profiling exercise using a 3rd party service provider (like MBTI) to who also process and hold data. We ensure these third parties are compliant with current regulation.

• Data retention period: We hold client and employee information for the duration of our work with that client. If we are informed of an employee leaving the business we archive their files accordingly both in our files and on the MBTI site and destroy any hard copies after 5 years. If an employee requests we remove their file we do so. Employees can also request their information is removed from third party services (like MBTI) by us or directly with the third party.
  Sharing your information: We do not share your information with third parties.

• Lawful basis: Legitimate interest
  The reason we use this basis: if you are a previous client of GWA or have shown a specific interest in our goods and services we may contact with information that we believe may be of interest to you.

• We process your information in the following ways: 

  • we hold your contact data using a GDPR compliant email system and may drop you an email from time to time.

• Data retention period: we regularly review contact details and remove them when they no longer seem to be of legitimate interest. You may contact us at any time to request that we remove your data.
  Sharing your information: We do not share your information with third parties.

If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.

Your individual rights

Under the GDPR your rights are as follows. You can read more about your rights in details here;

• the right to be informed;

• the right of access;

• the right to rectification;

• the right to erasure;

• the right to restrict processing;

• the right to data portability;

• the right to object; and

• the right not to be subject to automated decision-making including profiling.

 

You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.

We handle subject access requests in accordance with the GDPR. Please contact nikki@naturallyhi if you have a subject access request.

Internet cookies

We use cookies on our website to provide you with a better user experience. We do this by placing a small text file on your device / computer hard drive to track how you use the website, to record or log whether you have seen particular messages that we display, to keep you logged into the website where applicable, to display relevant adverts or content, referred you to a third party website.

Some cookies are required to enjoy and use the full functionality of this website.

We use a cookie control system which allows you to accept the use of cookies, and control which cookies are saved to your device / computer. Some cookies will be saved for specific time periods, where others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device, please see your web browser options.

Cookies we use :

 

Cookie name

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svSession | Permanent |Creates activities and BI

hs | Session | Security

incap_ses_${Proxy-ID}_${Site-ID} | Session | Security

incap_visid_${Proxy-ID}_${Site-ID} | Session | Security

nlbi_{ID} | Persistent cookie | Security

XSRF-TOKEN | Persistent cookie | Security

smSession | Two weeks | Identify logged in site members

 

Data security and protection

We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.

 

Transparent Privacy Explanations

We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.

 

Email marketing messages & subscription

Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the "Processing of your personal date" above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.

Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.

Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also unsubscribe from all MailChimp lists, by following this link, otherwise contact the EMS provider.

Our EMS provider is; Mailchimp; We hold the following information about you within our EMS system;

• Email address

• I.P address

• Subscription time & date

• Company name (if provided)