Privacy
This privacy notice tells you what to expect us to do with your personal information.
- Contact details
- What information we collect, use, and why
- Lawful bases and data protection rights
- Where we get personal information from
- How long we keep information
- Who we share information with
- Sharing information outside the UK
- How to complain
Contact details
Email - feedback@myprivateprogress.co.uk
Age restriction
My Private Progress and its digital resources are intended for adults aged 18 and over. We do not knowingly collect personal information from children.
What information we collect, use and why
We collect or use the following information to provide services and goods, including delivery:
- Names and contact details
- Purchase history
- Website usage and technical information
We collect or use the following to comply with legal requirements:
- Name
- Contact information
- Financial transaction information
- Any other personal information required to comply with legal obligations
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Purchase or service history
- Financial transaction information
- Correspondence
Privacy of your downloaded resources
The personal information described above relates to the administration of our website, purchases and customer enquiries. My Private Progress does not receive, access or store information you enter into your downloaded resources. Information entered into your downloaded resources remains private to you.
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
- Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
- Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
- Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
- Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
- Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for collection and use of your data
Our lawful basis for collecting or using personal information to provide services and goods is:
Contract - We have to collect or use information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our Lawful Basis for collecting or using personal information for legal requirements is:
Legal obligation - we have to use or collect your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our Lawful Basis for collecting or using personal information for dealing with queries, complaints or claims is:
Legitimate interests - we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are:
We have a legitimate interest in using limited personal information to respond to queries, manage complaints, resolve issues relating to purchases or services, and establish, exercise or defend legal claims where necessary.
This benefits My Private Progress and the individuals who contact us by allowing us to respond effectively, investigate concerns and resolve problems. We only use information that is relevant and necessary for the particular query, complaint or claim and do not use it for unrelated purposes.
We consider the impact on individuals to be limited because people would reasonably expect us to use the information they provide, along with relevant purchase or transaction information where necessary, to deal with their enquiry or complaint.
For website analytics, we rely on legitimate interests to understand how our website is used, maintain and improve performance, and identify technical issues.
IONOS SiteAnalytics provides statistical information about website use without using cookies and anonymises IP addresses after transmission. We consider this processing to have a limited impact on individuals because the information is used for statistical and technical purposes and is not used by My Private Progress to identify individual website visitors.
For more information on our legitimate interests as a lawful basis, you can contact us using the contact details set out above.
Where we get personal information from
We obtain personal information:
- Directly from you
- From suppliers or service providers
How long we keep information
We keep personal information for as long as necessary for the purpose for which it was collected and to meet any legal, accounting or reporting requirements.
Purchase and financial transaction records required for tax and accounting purposes are retained for the period required by law. As a self-employed business, relevant business records will generally be kept for at least 5 years after the 31 January Self Assessment submission deadline for the relevant tax year.
Information relating to enquiries, complaints or claims will be kept only for as long as reasonably necessary to deal with the matter and any related legal or administrative requirements.
Personal information processed by our service providers may be retained in accordance with their own legal and regulatory obligations and retention policies.
Who we share information with
Data processors
IONOS
IONOS provides website hosting and related website services, including the storage and processing of website data and visitor information.
Stripe Payments Europe Limited
Stripe provides payment processing services and processes customer payment and transaction information to facilitate purchases.
Others we share information with
Payhip
We use Payhip Limited to provide our online storefront and facilitate the purchase and delivery of our digital products. When you use the Payhip platform, Payhip processes personal information in accordance with its own privacy policy. Payment information is handled separately by the payment provider selected during checkout.
Payhip Privacy and Cookie Policy
Website analytics
Our website uses IONOS SiteAnalytics for statistical analysis and technical optimisation.
SiteAnalytics collects technical information about visits to the website, such as the requested page, referring website, browser and device type, operating system and time of access.
IP addresses are anonymised after transmission. IONOS states that SiteAnalytics uses pixel or log-file technology rather than cookies and does not store visitor information in a way that identifies individual visitors.
Sharing information outside the UK
Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.
Organisation name: Stripe LLC
Category of recipient: Payment processing and financial technology services
Country the personal information is sent to: United States of America
How the transfer complies with UK data protection law: The country or sector has been assessed as providing adequate protection to data subjects (also known as Adequacy Regulations or UK data bridge).
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
Email: feedback@myprivateprogress.co.uk
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the Information Commissioner’s Office (ICO).
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline: 0303 123 1113
Website: Make a complaint | ICO
