Privacy Policy
I take your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on how and why I collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact me or supervisory authorities in the event you have a complaint.
Key Terms:
‘I’, ‘me’ or ‘my’ means Artur Appazov.
‘You’ or ‘your’ means the person accessing or using this website or its content.
‘Personal data’ means any information relating to an identified or identifiable individual.
‘Special category personal data’ means personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data (when processed to uniquely identify an individual), data concerning health, sex life or sexual orientation.
‘Data subject’ means the individual who the personal data relates to.
I collect, use and am responsible for certain personal data about you. When I do so, I am subject to the EU General Data Protection Regulation (EU GDPR) in relation to services I offer to individuals and my operations in the European Economic Area (EEA), and to other laws that may be applicable to the subject matter of this Policy that are in force in jurisdictions relevant to my services offered to individuals worldwide.
1. Personal data I collect about you
I will collect and use the following personal data about you:
your name and contact information, including email address and telephone number and company details;
your billing information, transactions, and payment card information;
information about how you use this website, IT, communication and other systems;
your responses to surveys and promotions.
I collect and use this personal data for the purposes described in the section ‘How and why I use your personal data’ below.
2. How your personal data is collected
I collect most of this personal data directly from you — in person, by telephone, text or email and/or via this website. However, I may also collect information from cookies on this website. I may store some information (commonly known as a ‘Cookie’) on your computer when you look at this website. This information facilitates your use of this website and helps me to understand how this website is used. You can erase or block some cookies from your computer if you want to, however, certain services may not work correctly or at all if you set your browser not to accept cookies. This website is hosted on Squarespace. Please refer to Squarespace Cookie Policy for additional information.
3. How and why I use your personal data
Under data protection law, I can only use your personal data if I have a proper reason, eg:
where you have given consent;
to comply with my legal and regulatory obligations;
for the performance of a contract with you or to take steps at your request before entering into a contract; or
for the legitimate interests or those of a third party.
A legitimate interest is when I have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. I will carry out an assessment when relying on legitimate interests, to balance my interests against your own.
4. Marketing
4.1. I will use your personal data to send you updates (by email or post) about my services, including changes to my services, exclusive offers, promotions or new services.
4.2. I have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why I use your personal data’). This means I do not usually need your consent to send you marketing information. If I change my marketing approach in the future so that consent is needed, I will ask for this separately and clearly.
4.3. You have the right to opt out of receiving marketing communications at any time by:
contacting me using the form on my ‘Contact’ page or
using the ‘unsubscribe’ link in emails.
4.4. I may ask you to confirm or update your marketing preferences if you ask me to provide further services in the future, or if there are changes in the law, regulation, or the structure of my business.
4.5. I will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
5. Who I share your personal data with
5.1. I routinely share personal data with:
third parties I use to help deliver my services to you, eg payment service providers, companies who provide administrative services or sub-contractors;
other third parties I use to help me run my business, eg marketing agencies or website hosts;
third parties approved by you, eg social media sites you choose to link your account to or third party payment providers.
5.2. I only allow those organisations to handle your personal data if I am satisfied they take appropriate measures to protect your personal data. I also impose contractual obligations on them to ensure they can only use your personal data to provide services to me and to you.
5.3. I or the third parties mentioned above occasionally also share personal data with:
external auditors, eg in relation to the audit of accounts, in which case the recipient of the information will be bound by confidentiality obligations;
professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
law enforcement agencies, courts, tribunals and regulatory bodies to comply with legal and regulatory obligations;
other parties that have or may acquire control or ownership of my business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of my insolvency — usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
6. Where your personal data is held
6.1. Personal data may be held at my offices, on my secure CRM system, in my emails or on Dropbox, at third party agencies, service providers, representatives and agents as described above (see above: ‘Who I share your personal data with’).
6.2. Some of these third parties may be based outside the EEA. For more information, including on how I safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the EEA’.
7. How long your personal data will be kept
I will not keep your personal data for longer than I need it for the purpose for which it is used. For example, I will keep information about contracts for 6 years. Different retention periods apply for different types of personal data. Following the end of the relevant retention period, I will delete or anonymise your personal data.
8. Transferring your personal data out of EEA
8.1. Countries outside the EEA may have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for me to transfer your personal data to countries outside the EEA. In those cases I will comply with applicable EEA laws designed to ensure the privacy of your personal data.
8.2. I may transfer your personal data to my service providers located outside of the EEU.
8.3. Under data protection laws, I can only transfer your personal data to a country outside the EEA where:
the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR.
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
a specific exception applies under relevant data protection law.
8.4. Where I transfer your personal data outside the EEA, I do so on the basis of an adequacy regulation or (where this is not available) I enter into a contract to protect your rights. In the event I cannot or choose not to continue to rely on either of those mechanisms at any time, I will not transfer your personal data outside the EEA unless I can do so on the basis of an alternative mechanism or exception provided by EU data protection law and reflected in an update to this policy.
8.5. Any changes to the destinations to which I send personal data or in the transfer mechanisms I rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
9. Your rights
You have the following rights, which you can exercise free of charge:
Access — the right to be provided with a copy of your personal data
Rectification — the right to require that I correct any mistakes in your personal data
Erasure (also known as the right to be forgotten) — the right to require that I delete your personal data — in certain situations
Restriction of processing — the right to require that I restrict processing of your personal data in certain circumstances, eg if you contest the accuracy of the data
Data portability — the right to receive the personal data you provided to me, in a structured, commonly used and machine-readable format and/or transmit that data to a third party — in certain situations
To object — the right to object:
at any time to your personal data being processed for direct marketing (including profiling);
in certain other situations to my continued processing of your personal data, eg processing carried out for the purpose of my legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to automated individual decision making — the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consent — if you have provided me with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw your consent by contacting me. Withdrawing your consent will not affect the lawfulness of my use of your personal data in reliance on that consent before it was withdrawn.
10. Keeping your personal data secure
I have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. I limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
11. How to complain
Please contact me if you have any queries or concerns about my use of your personal data (see below ‘How to contact me’).
12. Changes to this privacy policy
This privacy notice was last updated on the 15th of March, 2023.
13. How to contact me
You can contact me using the form on my Contact page if you have any questions about this Privacy Policy or the information I hold about you, to exercise a right under data protection law or to make a complaint.