Privacy Policy.

Last Updated: 07.05.2024

Implicit respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our services and tell you about your privacy rights and how the Data Protection Law protects you.  

We take data protection very seriously and abide by Data Protection Law, which includes the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act (DPA) 2018 and other relevant privacy laws that govern the website and the services.

1. Purpose of this privacy policy

This privacy policy aims to give you information on how Implicit collects and processes your personal data through your use of this website and in the provision of the services, including any data you may provide through this website’s capture forms when you sign up to our newsletter or purchase service.

This privacy policy is also intended to notify you of our privacy practices when you are taking up our coaching, mentoring and/or business advisory services and will inform you of the type and categories of information that may be collected, disclosed and stored, how the information is used, with whom the information may be shared, what choices are available to you regarding the collection, use and distribution of the information, what kind of security procedures are in place to protect the loss, misuse or alteration of information under our control, your rights regarding your personal information and who to contact with questions or concerns.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements all other notices you may already have been provided or be provided during the services and is not intended to replace them.  

2. Controller
Implicit Advisory Limited is the controller and responsible for your personal data (collectively referred to as "Implicit", "we", "us" or "our" in this privacy policy).

There is an assigned person who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights.

3. Contact details

If you have any questions about this privacy policy or our privacy practices, please contact:

Full name of legal entity: Implicit Advisory Limited

Email address: info@theimplicit.co.uk

Postal address: C/O Alexander & Co. Centurion House, 129 Deansgate, Manchester M3 3WR.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

4. Your Legal Rights

Under Data Protection Law, you have the right to:

Request access to your personal data – this means that you can request a copy of your personal data
Request correction of your personal data – you can ask us to correct your personal data if it inaccurate or complete.
Request erasure of your personal data – under certain circumstances, you can ask us to delete your personal data. If we think there is a good reason to keep the information you have asked us to delete (e.g. to comply with regulatory requirements), we will let you know and explain our decision.
Object to processing of your personal data - You can object to us using your personal data if you want us to stop using it. We always comply with your request if you ask us to stop sending you marketing communications but in other cases, we decide whether we will continue. If we think there is a good reason for us to keep using the information, we will let you know and explain our decision.
Request restriction of processing your personal data - You can ask us to restrict how we use your personal data and temporarily limit the way we use it (e.g. whilst you check that the personal data we hold for you is correct). Request transfer of your personal data - You can ask us to send you or another organisation an electronic copy of your personal data
If you would like to exercise any of your legal rights, please contact: info@theimplicit.co.uk.

If we feel that your request is unfounded or excessive, we may choose not to action your request. If this happens, we will write to you to explain why we cannot action your request.  

5. What we may need from you

We 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. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We could refuse to comply with your request in circumstances these circumstances or where we do not have confirmation of your identity or enough information to process the request.

6. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 11 March 2022.  

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 by using the contact details above.

7. The data we collect about you

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).

We may collect, use, store and transfer different kinds of personal data about you (as both client and candidate) which we have grouped together as follows:

Identity Data includes first name, last name professional title or similar identifier.

Contact Data includes email address and telephone numbers.

Transaction Data includes details about prices quoted, services used or   purchased, costs applicable, sums owed, payments to and from you and other similar data.

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.

Usage Data includes information about how you use our website, products and services.

Enquiry Data includes your email address, details of your enquiry and any other details you provide for us to process your enquiry.

Other Data includes any other data you may provide in person in our coaching, mentoring or business advisory sessions or by telephone email or otherwise which is not specifically listed here, but will be used in accordance with this privacy policy or as otherwise advised at the time of collection, e.g. information provided to enable us to assist you as part of the services.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences, e.g. email, telephone, etc. We do not pass on your detail to third parties.

We do not collect any Special Category of Personal Data. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or 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 services we provide or contract we are trying to enter into with you. In this case, we may have to cancel a service you have with us. We will notify you if this is the case at the time.

8. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions -You (as the client or the candidate) may give us your Identity Data and Contact Data by filling in our contact form on the Implicit webpage or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

     o apply for our services                        
     o subscribe to our newsletter or to receive publications                        
     o request marketing to be sent to you                        
     o give us feedback or contact us.

Third parties or publicly available sources -We may from time to time receive personal data about you from public sources such as Identity and Contact Data from publicly available sources such as Companies House and HMRC based inside the UK.

Automated technologies or interactions. As you interact with our website, our web hosting service will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

9. How we use your personal data

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

Where it is necessary to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. Where we need to comply with a legal obligation.
Where you have consented to receiving marketing.    
Where you have provided your consent to receiving marketing message, you have the right to withdraw consent to marketing at any time by contacting us.

Some personal data is processed on the basis of Implicit’s legitimate interest in providing commercial coaching, mentoring and business advisory services, which we have outlined in the section below. Where we process your personal data for our legitimate interests, we have considered whether this processing is necessary for purpose and considered your rights and freedoms before processing.

The processing of client and candidate personal data is minimised as far as possible and will not be used for any purpose beyond carrying out the Purposes below.

10. Purposes for which we will use your personal data

We have set out information below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal grounds we are relying on to process your personal data where more than one ground has been set out in the table below.

Legal Basis

Our legitimate interest to help you find the right  service for you so we can get your business and help you.

Purpose we use your personal Data To respond to your enquiry.

This includes your identity; contact data any other information you provide us.  

Legal Basis

Our legitimate interest (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Purpose we use your personal Data

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) via GoDaddy.com. This may include personal data about your identity, contact, technical and usage.

Legal Basis  

As necessary for our legitimate interests (to keep our records updated and to study how   customers use our services)

Purpose we use your personal Data

Where we ask you to leave a review or provide feedback. This would consider your identity, contact and some transaction details.

Legal Basis

Necessary for our legitimate interests (to develop our products/services and grow our business)

Purpose we use your personal Data

To consider what suggestions and recommendations to you. This may include personal data about your identity, contact details, marketing preferences. See further details about marketing below.  

Legal Basis

Where you have consented to receiving marketing messages from us.

Purpose we use your personal Data

To send you blogs and newsletters where you have consented and requested to be sent these. We will process your identity and contact details to this. You can opt out of this at any time by emailing us at info@theimplicit.co.uk  

Legal Basis
‍
Where the processing is necessary to enter into, or perform a contract for services.

Purpose we use your personal DataNotifying you about changes to our terms or privacy policy.

We may use your contact details to do this.  

Legal Basis

Where the processing is necessary to enter into, or perform a contract for services

Purpose we use your personal Data

Where we register you as a new customer, which will include your identity and contact data.  

To process and deliver your order and the services including:

• Coaching / mentoring and business advisory  
• Manage invoicing, fees and charges.
• Collect and recover money owed to us.

This may include Identity, contact, transaction or other personal data you provide during coaching or mentoring.  

Legal Basis

Necessary to comply with a legal obligation.

Purpose we use your personal Data

Where we process personal data for the prevention of fraud.

This may include identity data or Usage data. We retain some information for audit purposes and to pay UK taxes. This may include Identity, Contact or Customer Data.  

11. Change of purpose

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.  

If we need to use your personal data for an unrelated purpose, we will notify you, and were required by law, ask for your consent. Otherwise we will explain the legal basis which allows us to do so.

12. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. When you join our mailing list, we will ask you to make certain decisions about your personal data use, specifically the type of content you would like to receive and how you wish to be contacted.

Promotional offers from us

We may use your Identity, Contact and Customer Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).  You will only receive marketing communications from us if you have requested information from us.

Feedback and testimonials

We may from time to time contact you to ask you for your feedback on the services and to ask you to provide a review. If we ask you to provide a testimonial we want to publish, we will always get your express permission and we will ask whether you would prefer it to be anonymous.

Third-party marketing  

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes and opt-out options where you do consent for this type of marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time using the contact details above.  Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us to purchase a service, for example billing or requests to rate or provide feedback about your service experience.

13. Sharing your personal data

We use third parties to provide us with services, professional advice or perform regulatory and reporting functions and may share your personal data with these parties set out below or notified from time to time for the purposes set out in the table Purposes for which we will use your personal data above.

Service providers based the UK who provide IT and system administration services. For example, our website is hosted on the GoDaddy web hosting service by:· GoDaddy.com, LLC, a Delaware limited liability company (“GoDaddy”).  Professional advisers acting as controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services. Our accountants are: · Alexander & Co. Centurion House, 129 Deansgate, Manchester M3 3WR.
HM Revenue & Customs, regulators and other authorities acting as controllers based in the UK who require reporting of processing activities in certain circumstances. We may need to share your data with other service providers or professional advisors from time to time and will add these parties to this list should that be the case.

There also may be disclosures to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.  

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.

14. Cookies

Our website uses cookies. In addition to our cookie banner where you can accept or reject cookies, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

15. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

16. International transfers

We share your personal data with our web hosting service GoDaddy (who are based in and carry out the webhosting services from the USA) who may share such information with its affiliates and notified sub-processors. This will involve transferring your data outside the UK.  

For more information you can access the data processor addendum we have with GoDaddy by visiting https://uk.godaddy.com/legal/
agreements/data-processing-addendum.  

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

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.  Where we use certain service providers, we may use specific contracts, such as the International Data Transfer Agreement, approved for use in the UK, or the Standard Contractual Clauses, approved for use in the EEA, which give personal data the same protection it has in the UK.  Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

17. Data security

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, agents, contractors 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.

18. Data retention

How long will you use my personal data for?

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.

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.

For the purpose of bringing of defending ourselves in the event of a legal claim, we keep basic information about our customers (including Contact, Identity and Transaction Data) for seven years after our contract for services has ended.

Some data will be retained under the legal obligation for audit purposes and to pay UK taxes and we may need to process your data to obtain professional advice.

In some circumstances you can ask us to delete your data see your legal rights above for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.  

Glossary:

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. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

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