Privacy Notice

This is Flourish ltd is committed to protecting your privacy and ensuring

the security of your personal information. We use your information as set

out in this Privacy Notice.

Information About Us

This is Flourish ltd Ltd.

Registered office: 4th Floor Silverstream House, 45 Fitzroy Street,

London, England, W1T 6EB

Company number 11698228

When we refer to ‘us’ or ‘we’ in this notice, we are referring to the owners

This is Flourish ltd Management Ltd. References made to ‘you’ or ‘your’

refers to any individual whose personal information we process.

Introduction

We will treat your personal information as confidential and in accordance

with data protection legislation; your personal information will only be

shared with others in accordance with this Privacy Notice.

This Privacy Notice outlines:

 What personal information is

 Types of personal information we collect and why

 The legal basis for processing your personal information

 How your personal information is shared

 How long your personal information is retained

 How we keep your personal information secure

 Your rights in relation to your personal information

 How to contact us or to make a complaint

 How future changes to this Privacy Notice will be dealt with

1. Personal Information

Personal information is any information about you. This could include

information such as name, date of birth, contact details, bank account

details or any information about your circumstances.

Under data protection legislation certain personal information relating to

health, racial or ethnic origin, religious beliefs or political opinions and

sexual orientation is classified as ‘special’ due to it being sensitive

information. We need to have further justifications for collecting, storing

and using this type of personal information. Please see section 2.

Where this privacy notice makes reference to personal information it will

include personal data, and where relevant, special categories of personal

data.

2. Types of Personal Information Collected and Why

Contract information and other correspondence

Whenever you engage with us (by email, telephone, post, SMS or via our

website) we may collect your full name and contact details (such as phone

number, email address and postal address) from you.

When you enter into a contract with us (or someone does so on your

behalf) there will be personal information about you relating to that

contract such as your name, contact details, contract details, and

correspondence with us about the contract that will be required to enable

us to carry out the contract with you.

If the information is not provided, we will be unable to perform our

contract with you and may not be able to provide services to you or

continue to provide certain services to you. When this is the case, this will

be explained at the point when information is collected from you

When you are entering into a contract certain information is generally

mandatory including the information set out above plus any information

required for us to carry out anti money laundering checks.

Call information. We may also collect details of phone numbers used to

call our organisation and the date, time and duration of any calls. Please

note that if we record your calls to or from us, we will inform you of this.

Marketing

If you subscribe to receive marketing information or news we may collect

your name and contact details (such as your email address, phone number

or address) in order to send you information about events, goods or

services which you might be interested in. We may collect this directly

from you, or through a third party. If a third party collected your name and

contact details, they will only pass those details to us for marketing

purposes if you have given your permission.

You always have the right to ‘opt out’ of receiving our marketing. You can

exercise that right at any time by contacting us at hello@This is

Flourish.co.uk . If we send you any marketing emails, we will always

provide an unsubscribe option to allow you to opt out of any further

marketing emails. We may still need to contact you for administrative or

operational purposes, but we will make sure that those communications

don’t include direct marketing.

We never share your name or contact details with third parties for

marketing purposes unless we have your ‘opt-in’ consent to share your

details with a specific third party for them to send you marketing. We do

use third party service providers to send out our marketing, but we only

allow them to use that information where they have agreed to treat the

information confidentially and to keep it secure.

Website information

We may collect information about you and your use of our website via

technical means such as cookies, webpage counters and other analytics

tools. We use this as necessary for our legitimate interests in

administering our website and to ensure it operates effectively and

securely.

For detailed information on the cookies we use and the purposes for which

we use them see cookie notice.

Our website may, from time to time, contain links to third party websites.

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 notice

of every website you visit.

Employee information

If you work for one of our customers, suppliers or business partners, the

information we collect about you may include your contact information,

details of your employment and our relationship with you. This

information may be collected directly from you or provided by your

organisation. We use this as necessary for our legitimate interests in

managing our relationship with your organisation and to comply with our

legal obligations.

Information collected at our premises

Visitor information.

We collect information about visitors to our premises. We may record

information on your visit, including the date and time, who you are visiting,

your name, employer, contact details and vehicle registration number. If

you have an accident at our premises, this may include an account of your

accident.

CCTV.

We may operate CCTV at our premises which may record you and

your activities. We display notices to make it clear what areas are subject

to surveillance. We only release footage following a warrant or formal

request from law enforcement, or as necessary in relation to disputes or

requests from insurers.

The information is to ensure site security and visitor safety as well as

administering parking.

Job applicants

We collect and hold information provided to us by direct job applications

or from recruitment agencies and use this in evaluating candidates,

recording our recruitment activities, to enter into an employment contract

and to enable us to perform our employment law obligations and

rights. For successful applicants, information will be used in accordance

with our internal privacy notice which will be provided.

If you are listed as a referee by a job applicant or an emergency contact by

someone who works for us, we will hold your name, contact details and

details of your relationship with that worker. We will use this only to

contact you to carry out our obligations under employment law.

Legal claims

If we consider there to be a risk that we may need to defend or bring legal

claims, we may retain your personal information as necessary for our

legitimate interests in ensuring that we can properly bring or defend legal

claims. We may also need to share this information with our insurers or

legal advisers.

Information we receive from third parties

We work with third parties (including, for example, business partners,

sub-contractors in technical, payment and delivery services, advertising

networks, analytics providers, search information providers and credit

reference agencies) who may provide us with information about you, to be

used as set out in this notice.

Special categories of data

We may collect and use the following “special categories” of more

sensitive personal information in the following situations:

Information about your health, including medical records (in relation to

insurance claims for the legitimate interest of managing the property and

as necessary to establish, exercise or defend legal claims).

3. The Legal basis for processing your personal information

We will only use your personal information when the law allows us to do

so. Although in limited circumstances we may use your information

because you have specifically consented to it, we generally rely on the

following legal bases to use your information:

 For employment-related purposes

 Where we need information to perform the contract, we have

entered into with you

 Where we need to comply with a legal obligation

 Where the processing is necessary for us to carry out activities for

which it is in our legitimate interests (or those of a third party) to

do so and provided that your interests and fundamental rights do

not override those interests.

We will only use your personal information for the purposes for which it

was collected unless we reasonably consider that we need to use it for

another reason and that reason is compatible with the original purpose. If

we need to use your personal information for an unrelated purpose, we

will notify you and we will explain the legal basis which allows us to do

so.

4. How your personal information is shared

As well as any sharing listed above, we may also share your information

with third parties, including third-party service providers (for example,

those providing legal advice, IT services or payment processing). Third

parties are required to respect the security of your personal information

and to treat it in accordance with the law. We never sell your data to third

parties.

We may share your personal information with third parties if we are under

a duty to disclose or share your personal information in order to comply

with any legal obligation.

All our third-party service providers are required to take appropriate

security measures to protect your personal information. Where third

parties process your personal information on our behalf as ‘data

processors’ they must do so only on our instructions and where they have

agreed to treat the information confidentially and to keep it secure.

We may also need to share your personal information with a regulator or

to otherwise comply with the law.

Lawful Basis 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 or regulatory obligation means processing your

personal data where it is necessary for compliance with a legal or

regulatory obligation that we are subject to.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile 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 services and offers may be

relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested

information from us or if you provided us with your details when you

entered a competition or registered for a promotion and, in each case, you

have not opted out of receiving that marketing.

Opting out

You can ask us or third parties to stop sending you marketing messages at

any time by unchecking relevant boxes to adjust your marketing

preferences or by following the opt-out links on any marketing message

sent to you or by contacting us at any time.

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 www.This is Flourish ltdmanagement.co.uk/cookies

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 we need to use your personal data for an unrelated purpose, we will

notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your

knowledge or consent, in compliance with the above rules, where this is

required or permitted by law.

5. Disclosures of your personal data

In certain circumstances, we may be legally required to share certain data

held by us, which may include your personal data, for example where we

are complying with legal obligations, a court order, or a governmental

authority.

We may have to share your personal data with 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 notice.

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.

6. International Transfers

We do not transfer your personal data outside the European Economic

Area (EEA).

7. 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.

8. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil

the purposes we collected it for, including for the purposes of satisfying

any legal, accounting, or reporting requirements.

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 requirements.

In some circumstances you can ask us to delete your data see below for

further information.

In some circumstances we may 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in

relation to your personal data:

· Request access to your personal data (commonly known as a “data

subject access request”). This enables you to receive a copy of the

personal data we hold about you and to check that we are lawfully

processing it.

· Request correction of the personal data that we hold about you. This

enables you to have any incomplete or inaccurate data we hold about you

corrected, though we may need to verify the accuracy of the new data you

provide to us.

· Request erasure of your personal data. This enables you to ask us to

delete or remove personal data where there is no good reason for us

continuing to process it. You also have the right to ask us to delete or

remove your personal data where you have successfully exercised your

right to object to processing (see below), where we may have processed

your information unlawfully or where we are required to erase your

personal data to comply with local law. Note, however, that we may not

always be able to comply with your request of erasure for specific legal

reasons which will be notified to you, if applicable, at the time of your

request.

· Object to processing of your personal data where we are relying on a

legitimate interest (or those of a third party) and there is something about

your particular situation which makes you want to object to processing on

this ground as you feel it impacts on your fundamental rights and

freedoms. You also have the right to object where we are processing your

personal data for direct marketing purposes. In some cases, we may

demonstrate that we have compelling legitimate grounds to process your

information which override your rights and freedoms.

· Request restriction of processing of your personal data. This enables

you to ask us to suspend the processing of your personal data in the

following scenarios: (a) if you want us to establish the data’s accuracy; (b)

where our use of the data is unlawful but you do not want us to erase it;

you need it to establish, exercise or defend legal claims; or (d) you have

objected to our use of your data but we need to verify whether we have

overriding legitimate grounds to use it.

· Request the transfer of your personal data to you or to a third party.

We will provide to you, or a third party you have chosen, your personal

data in a structured, commonly used, machine-readable format. Note that

this right only applies to automated information which you initially

provided consent for us to use or where we used the information to

perform a contract with you.

· Withdraw consent at any time where we are relying on consent to

process your personal data. However, this will not affect the lawfulness of

any processing carried out before you withdraw your consent. If you

withdraw your consent, we may not be able to provide certain products or

services to you. We will advise you if this is the case at the time you

withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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. Alternatively, we

may refuse to comply with your request in these circumstances.

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.

Time limit to respond

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 and keep you updated.