Privacy Policy
PRIVACY POLICY

This Privacy notice was last updated on May 20, 2018

 

YOU MATTER

 

Dare to Care Leadership’s mission is to develop great tools and services that help our users to be more effective, productive and successful in their personal and professional lives. We are convinced that a fair relationship with our users is very important. Therefore, we are fully committed to protect your privacy and to communicate how we collect and process data transparently.

 

The data controller for this website is Leona Bishop, the sole owner of Dare to Care Leadership / Functional Fluency Caribbean(referred to as “we”, “us” or “our” in this privacy notice). Dare to Care Leadership / Functional Fluency Caribbean is registered at the Chamber of Commerce, Curaçao

 

Contact details:

leona@daretocareleadership.com

leona@ffcaribbean.net

Jan Sofat 51 North

Curaçao

 

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.daretocareleadership.com and www.ffcaribbean.net.

 

This policy governs the manner in which Dare to Care Leadership and Functional Fluency Caribbean collects, uses, maintains and discloses information collected from users (each, a “User”) of the www.daretocareleadership.com & www.ffcaribbean.net website (“Site”). This privacy policy applies to the Site and all products and services offered by Dare to Care Leadership & Functional Fluency Caribbean.

 

By providing us with your data, you warrant to us that you are over 18 years of age.

 

WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

 

Personal data means any information capable of identifying an individual. It does not include anonymized data. Dare to Care Leadership & Functional Fluency Caribbean may collect and use Users personal information for the following purposes:

 

  • To improve customer service
    Information you provide helps us respond to your customer service requests and support needs more efficiently.
  • To personalize user experience
    We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
  • To improve our Site
    We may use feedback you provide to improve our products and services.
  • To process payments
    We may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.
  • To send periodic emails
    We may use the email address to send User information and updates pertaining to their order. It may also be used to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

 

We may process the following categories of personal data about you:

 

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

 

  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, or purchase details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

 

  • User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

 

  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

 

  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

 

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interest, which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

 

Sensitive Data

 

We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences. We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at: leona@daretocareleadership.com or leona@ffcaribbean.net. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

 

HOW WE COLLECT YOUR PERSONAL DATA

 

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website.

 

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators. We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

 

MARKETING COMMUNICATIONS 

 

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business). Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time. We will not share your personal data with any third party for their own marketing purposes.

 

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at leona@daretocareleadership.com or leona@ffcaribbean.net at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

 

DISCLOSURES OF YOUR PERSONAL DATA

 

We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers
  • Government bodies that require us to report processing activities.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

INTERNATIONAL TRANSFERS

 

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission. Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

 

  • We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

 

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

 

DATA SECURITY

 

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

 

DATA RETENTION

 

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances, we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

YOUR LEGAL RIGHTS

 

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

 

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

 

If you wish to exercise any of the rights set out above, please email us at leona@daretocareleadership.com or leona@ffcaribbean.net.

 

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 or refuse to comply with your request in these circumstances. 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.

 

We 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, we will notify you.

 

If you are not happy with any aspect of how we collect and use your data, you have the right to initiate a complaint with courts of the appropriate Member State and with the supervisory authority of the Member State where you reside, where you work, or where the infringement occurred. Please find the GDPR Complaint-Process Map.

 

We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

 

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. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

PRIVACY POLICY CHANGES

 

Although most changes are likely to be minor, Dare to Care Leadership / Functional Fluency Caribbean may change its Privacy Policy from time to time, and in Dare to Care Leadership / Functional Fluency Caribbean’s sole discretion. Dare to Care Leadership / Functional Fluency Caribbean encourages visitors to frequently check this page for any changes to its Privacy Policy. If you have a WordPress.com account, you should also check your blog’s dashboard for alerts to these changes. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

 

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy. &nbsp If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

 

Contact Details

 

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at leona@daretocareleadership.com or leona@ffcaribbean.net.

 

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:
leona@daretocareleadership.com or leona@ffcaribbean.net

Jan Sofat 51 North

Curaçao