Data

2. The data I collect about you

It is presumed within and correlating to all documents that a Contractor may also be known as a Viewing party. Either the Inventor or Contractor may terminate this Agreement in the event of a material breach of the Agreement, which is not cured within one month of written notice to the other of such breach.

Either the Inventor or Contractor may terminate this Agreement for its sole convenience by giving a 90 Days advance notice in writing. In such event, Contractor shall complete any ongoing assignment unless otherwise advised by the Inventor.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

I may collect, use, store and transfer different kinds of personal data about you, which may fall into the following categories depending on your interaction with Singh Loyal Portfolio:

• Website users
• Clients (potential and existing)
• Shareholders
• Suppliers (potential and existing)
• Future endeavours and projects
• Budget restraints

I have then grouped together the data types within these categories as follows:

• Identity Data includes first name and last name.
• Contact Data includes company name and email address.
• Financial Data includes bank account and payment card details and data about your transactions with me.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username or similar identifier and password, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use my website, products and services.
• Marketing and Market Research Data includes your preferences in receiving marketing from me, participating in surveys and providing feedback to me, and receiving industry updates and regulatory news from me and my third parties, and your communication preferences.
• Communications Data includes all communications I have with you whether by email, post, phone or otherwise.

I may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data
Where I need to collect personal data by law, or under the terms of a contract I have with you and you fail to provide that data when requested, I may not be able to perform the contract I have or are trying to enter into with you (for example, to provide you with goods or services). In this case, I may have to cancel a product or service you have with me but I will notify you if this is the case at the time.

3. How is your personal data collected?

I use different methods to collect data from and about you. These methods are dependent upon your interactions with Singh Loyal, as follows:

Website users

• Automated technologies or interactions: As you interact with my website, I may automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies, server logs and other similar technologies. Please see my privacy settings for further details.

Third parties or publicly available sources: I may receive personal data about you from various third parties and public sources as set out below.

Technical Data from the following parties:

• analytics, storage, tools and media providers based in and outside the EU;
• IP tracking service providers based in the EU;
• automated quality control tools based in the EU;
• automated security and compliance tools based outside the EU;
• social media and media networks, such as Twitter, LinkedIn, Instagram, YouTube and Vimeo, based outside the EU; and
• email distribution and survey providers based outside the EU.

Clients (potential and existing)

• apply for my products or services;
• subscribe to my service or publications;
• request marketing to be sent to you;
• enter a survey or give me some feedback; or
• provide information as part of your corporate communications project and proofing process.
• Identity and Contact Data from company advisers, such as financial public relations and investor relations consultancies, stockbrokers, lawyers, registrars and membership bodies/lobby groups based in the EU.
• Identity and Contact Data from data brokers, aggregators or industry bodies based in the EU.
• Identity and Contact Data from email distribution providers based outside the EU.
• Identity and Contact Data from publicly availably social media sources such Twitter, Instagram and LinkedIn.
• Identity and Contact Data from publicly availably sources such as Companies House and the electoral register based in the EU.
• Identity and Contact Data from customer relationship management tools.

Shareholders

Suppliers (potential and existing)

4. How I use your personal data

Information about the types of lawful basis that I will rely on to process your personal data is provided below.

Generally, I do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting me at singh2k8@hotmail.com.

Purposes for which I will use your personal data
I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.

Note that I may process your personal data for more than one lawful ground depending on the specific purpose for which I are using your data. Please contact me if you need details about the specific legal ground I are relying on to process your personal data where more than one ground has been set out in the table below.

Lawful basis for processing including basis of legitimate interest 
a. Performance of a contract with you

Type of data
a. Identity
b. Contact
c. Financial
d. Marketing and Market Research
e. Communications

Lawful basis for processing including basis of legitimate interest 
a. Performance of a contract with you
b. Necessary for my legitimate interests (to recover debts due to myself)

Type of data:
a. Identity
b. Contact
c. Profile
d. Marketing and Market Research
e. Communications

Lawful basis for processing including basis of legitimate interest 
a. Performance of a contract with you
b. Necessary to comply with a legal obligation
c. Necessary for my legitimate interests (to keep my records updated, to keep my clients up to date and to study how clients use my products/services)

Lawful basis for processing including basis of legitimate interest 
a. Performance of a contract with you
b. Necessary for my legitimate interests (to study how clients use my products/services and/or find my events, using the findings to develop and grow my business)

Lawful basis for processing including basis of legitimate interest 
Necessary for my legitimate interests (to develop my products/services and grow my business)

Lawful basis for processing including basis of legitimate interest 
Necessary for my legitimate interests (for running my business, provision of administration and IT services and network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation
Necessary to carry out and provide corporate communications contracts, products and services

Lawful basis for processing including basis of legitimate interest 
a. Performance of a contract with you
b. Necessary to carry out and provide corporate communications contracts, products and services

Lawful basis for processing including basis of legitimate interest 
Necessary for my legitimate interests (to define types of clients for my products and services, to keep my website updated and relevant, to develop my business and to inform my marketing strategy)

Lawful basis for processing including basis of legitimate interest 
Necessary for my legitimate interests (to provide important company, industry and regulatory information and news, to study how clients use my products/services, to deliver relevant events, to develop my client relationships, to grow my business and to inform my marketing and communications strategy)

Lawful basis for processing including basis of legitimate interest 
a. Performance of a contract with you
b. Necessary for my legitimate interests (to carry out and provide corporate communications contracts, products and services)

Lawful basis for processing including basis of legitimate interest 
a. Performance of a contract with you
b. Necessary for my legitimate interests (to carry out and provide corporate communications contracts, products and services)

Lawful basis for processing including basis of legitimate interest 
a. Performance of a contract with a company that you have invested in
b. Necessary for my legitimate interests (in carrying out corporate communications services and consultancy)

Marketing
I strive to provide you with choices regarding certain personal data uses, particularly around marketing and communications. I have established the following personal data control mechanisms:

Promotional offers from me
I may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what I think you may want or need, or what may be of interest to you. This is how I decide which products, services and offers may be relevant for you (I call this marketing).

You will receive marketing communications from me if you have requested information from me, purchased goods or services from me or expressed an interest in my products and services or if you have attended one of my events and, in each case, you have not opted out of receiving that marketing.

Third-party marketing
I will get your express opt-in consent before I share your personal data with any company outside Flathill Communications Group plc, of which Design Portfolio is a subsidiary, for marketing purposes

Opting out
You can ask me or third parties to stop sending you marketing messages at any time by contacting me at singh2k8@hotmail.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to myself as a result of a product/service purchase or experience or other transactions

5. Disclosures of your personal data

I may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above.

6. International transfers

Wherever possible I do not transfer your personal data outside the European Economic Area (EEA).

Some of my external third parties are based outside the European Economic Area (EEA) so their processing of your personal data may sometimes involve a transfer of data outside the EEA.

Whenever I transfer your personal data out of the EEA, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact me at singh2k8@hotmail.com if you would like further information on the specific mechanism used by myself when transferring your personal data out of the EEA.
 

7. Data security

I 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, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.

I 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 I am legally required to do so.
 

8. Data retention

How long will you use my personal data for?
I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

By law I have to keep basic information about my clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease to be clients for financial and legal purposes.

In some circumstances you can ask me to delete your data; see Request erasure below for further information.

In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case I may use this information indefinitely without further notice to you.

Legality

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact me at singh2k8@hotmail.com.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

What I may need from you
I may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
I try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.
 

10. Glossary

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests. I do not use your personal data for activities where our interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). You can obtain further information about how I assess my legitimate interests against any potential impact on you in respect of specific activities by contacting me at  singh2k8@hotmail.com.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.

THIRD PARTIES
Internal Third Parties 
Other companies in the Flathill Communications Group (The Design Portfolio Marketing Services Limited, The Design Portfolio Marketing Services Inc. and The Communications Portfolio Limited) acting as joint processors and who are based in the United Kingdom and the US and will provide corporate communications consultancy and services.

YOUR LEGAL RIGHTS
You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.

Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where my use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where I used the information to perform a contract with you.

Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.

• Identity and Contact Data from providers of data feeds and hosting services provided in the EU and outside the EU.
• Direct interactions.You may give us your Identity, Contact, Communications, Marketing and Research, and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Self-editing tools. As you interact with my self-editing tools or my website content management system (CMS),you will be required to use a username and password to provide initial access and I will collect this Profile Data. I may also automatically collect Technical Data and Usage Data about your equipment, editing actions and patterns. I collect this personal data by using cookies, server logs and other similar technologies. Please see my cookie policy for further details.
• Third parties or publicly available sources. I may receive personal data about you from various third parties and public sources as set out below.
• Indirect interactions. You may indirectly give us your Identity and Contact Data by investing in a company that I provide corporate reporting services for and via that company’s registrar, who holds the shareholder register that I will use to distribute the corporate reports and associated ancillaries.

Direct interactions. You may give us your Identity, Contact, Correspondence and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• provide us with a quotation for your products or services;
• deliver a product or service to us;
• subscribe to my service or publications;
• request marketing to be sent to you;
• take part in a survey; or
• give us some feedback.

Third parties or publicly available sources. I may receive personal data about you from various third parties as set out below.

• Identity and Contact Data from other suppliers and contacts within the industry and largely based in the EU.
• Identity and Contact Data from potential clients based in the EU.

I will only use your personal data when the law allows us to. Most commonly, I will use your personal data in the following circumstances:

• where I need to perform the contract I am about to enter into or have entered into with you;
• where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or where I need to comply with a legal or regulatory obligation.
   
• To register you as a new client or supplier 

Type of data
a.  Identity
b. Contact
c. Financial
d. Communications

• To process and deliver my products and services including: 
  a. Managing payments, fees and charges
  b. Collecting and recovering money owed to us
• To manage my relationship with you, which will include:
  a. Notifying you about changes to my terms or privacy policy
  b. Asking you to take part in a survey
  c. Providing latest news or updates on the industry and regulatory environment
• To enable you to complete a survey
   

Type of data
a. Identity
b. Contact
c. Profile
d. Usage
e. Marketing and Market Research
f. Communications

• To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data
a. Identity
b. Contact
c. Technical
d. Usage
e. Profile
f. Communications

• To administer and protect my business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  
  Type of data
  a. Identity
  b. Contact
  c. Technical
  d. Usage
  e. Profile
   
• To deliver data feeds, CRM and social media tools to my website, where relevant, and those of my clients, to enhance the user and business experience and provide relevant information
  
  Type of data
  a. Identity
  b. Contact
  c. Profile
  d. Usage
  e. Marketing and Market Research
   
• To use data analytics, IP tracking and automated quality control tools to improve my website, products/services, marketing, client relationships and experiences

Type of data
a. Technical
b. Usage
c. Profile

• To deliver relevant website content and marketing, research, events information or communications information to you and measure or understand the effectiveness of the marketing, research or communications information I serve to you

Type of data
a. Identity
b. Contact
c. Profile
d. Usage
e. Marketing and Market Research
f. Communications
g. Technical

• To deliver corporate communications projects which may require you to share your signature and photograph with us for inclusion in an annual report or website

Type of data

a. Identity
b. Communications

• To deliver corporate communications projects using self-editing tools which require a username and password
   

Type of data
a. Identity
b. Contact
c. Profile
d. Usage
e. Communications

• To deliver corporate reports using a shareholder register that you are listed on 

Type of data
a. Identity
b. Contact

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.

Third parties to whom I may choose to sell, transfer, or merge parts of my business or my assets. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy notice.

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my 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 my instructions.

I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where I use providers based in the US, I may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

Digital service providers acting as processors, operating in the EU, who provide a number of services, including but restricted to data feeds, hosting, SSL, data analysis, CRM, video streaming, social media and sharing services.

Professional advisers including lawyers, bankers, auditors and insurers based the United States, Brazil, China, Singapore and India who provide banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.

Marketing services providers acting as processors including mailing and survey companies operating in and outside of the EU who provide distribution, reporting and analysis of emails and surveys.