Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

“Account”
means an account required to access and/or use certain areas and features of Our
Sites
“Cookie”
means a small text file placed on your computer or device by Our Sites when you visit
certain parts of
Our Sites and/or when you use certain features of Our Sites. Information about the use of Cookies by Our
Sites is set out in section 12
“Our Sites”
means these websites www.freshstart.direct
and www.freshstart.online
“UK and EU Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive)
Regulations 2003
as amended in 2004, 2011, 2015 and Data Protection Act 2018
“We/Us/Our”
means Fresh Start Direct Ltd, a limited company registered in England under Company
Registration
number 11472627, whose registered address is 45 Queen Street, Deal, Kent and whose main trading address
is Castle House, Castle Hill Avenue, Folkestone. CT20 2TQ.

Introduction

We understand that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Sites and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Sites. Please read this Web Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Web Privacy Policy is deemed to occur upon your first use of Our Sites. If you do not accept and agree with this Privacy Policy, you must stop using Our Sites immediately.

  1. Information About Us

    Our Sites, https://www.freshstart.direct and www.freshstart.online are owned and operated by Fresh Start Direct Ltd, a limited company registered in England under Company Registration Number 11472627, whose registered address is 45 Queen Street, Deal, Kent and whose main Web Privacy and Cookie Policy Page 4 Fresh Start Direct Ltd © 2018 trading address is Castle House, Castle Hill Avenue, Folkestone, CT20 2TQ. Our VAT number is 185 3306 06. Registered with the Information Commissioner, number ZA462980.

  2. What Does This Policy Cover?

    This Policy applies only to your use of Our Sites. It does not extend to any websites that are linked to from Our Sites (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

  3. What Data Do We Collect?

    Some data will be collected automatically by Our Sites, other data will only be collected if you voluntarily submit it, for example, when completing a Booking Form. Depending upon your use of Our Sites, We may collect some or all of the following data:

    1. Names
    2. Date of birth
    3. Gender
    4. Business/Company name
    5. Job title
    6. Profession
    7. Contact information, such as email addresses and telephone numbers
    8. Demographic information such as post code, preferences and interests
    9. Information about a student that you are referring to us
    10. Payment and financial information
    11. IP address (automatically collected)
    12. Web browser type and version (automatically collected)
    13. Operating system (automatically collected)
    14. A list of URLs starting with referring Sites, your activity on Our Sites, and the Sites you
      exit to (automatically collected).
  4. How Do We Use Your Data?

    1. All personal data is stored securely in accordance with the principles of the Data Protection Act 2018. For more details on security see section 5.
    2. We use your data to provide the best possible services to you. This includes:
      1. Providing and managing your access to Our Sites
      2. Personalising and tailoring your experience on Our Sites
      3. Personalising and tailoring Our services for you
      4. Responding to communications from you
      5. Keeping a record of our communication and work carried out with you or on your behalf
      6. Market research
      7. Analysing your use of Our Sites and gathering feedback to enable Us to continually improve
        Our Sites and your user experience
      8. Meeting the necessary requirement and needs of our business.
    3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and or telephone and or text messageand or post with information, news and offers on Our Services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011, 2015 and the Data Protection Act 2018.
  5. How and Where Do We Store Your Data?

    1. We only keep your data for as long as We need to in order to use it as described in section 4, and or for as long as We have your permission to keep it. Please see Our Privacy Notice for further details.
    2. Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
    3. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Sites.
    4. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
  6. Do We Share Your Data?

    1. We may, with your permission, share your data with other companies in Our group.
    2. We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers and other information. All such data will be anonymised and will not include any personally identifying information.
    3. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information; for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us. Data will only be shared and used within the bounds of the law.
  7. What Happens If Our Business Changes Hands?

    1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be Web Privacy and Cookie Policy Page 6 Fresh Start Direct Ltd © 2018 transferred along with that part and the new owner or newly controlling party will, under the terms of Our Data Protection Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
    2. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. You will not be given the choice to have your data deleted or withheld from the new owner or controller.
  8. How Can You Control Your Data?

    1. When you submit information via Our Sites, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails.
    2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
    3. Please read Our Privacy Notice for future information and Our Data Protection Policy.
  9. Your Right to Withhold Information

    1. You may access certain areas of Our Sites without providing any data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.
    2. You may restrict your internet browser’s use of Cookies. For more information, see section 11 and the Privacy settings of your Browser.
  10. How Can You Access Your Data?

    You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at dataprotectionofficer@freshstart.direct or using the contact details in section 12. All Data Access Requests must be made in writing and may take up to 30 days to fulfilled.

  11. Cookies

    Our Sites may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve Our services. Our Sites also uses analytics services provided by Google Analytics and Opentracker, which also use Cookies. WebSites analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Sites. You can restrict or suspend the use of Cookies from within the Privacy settings of your Browser.

  12. Contacting Us

    If you have any questions about Our Sites or this Web Privacy and Cookie Policy, please contact Us by email at enquiries@freshstart.direct, by telephone on 0203 797 6417, or by post to the Data Protection Officer, Castle House, Castle Hill Avenue, Folkestone, CT20 2TQ. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 10). Data Access Requests must be made in writing and accompanied with a form of recognised identification as proof of your right to make the request. Further information is available in Our Data Protection Policy.

  13. Changes to Our Web Privacy Policy

    We may change this Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Sites and you will be deemed to have accepted the terms of this Policy on your first use of Our Sites following the alterations. We recommend that you check this page regularly to keep up-to-date.

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