Privacy & Cookie Policy
www.top2percent.co.uk Privacy Policy
Type of website: Business Services
Effective date: 1st October, 2023
www.top2percent.co.uk (the "Site") is owned and operated by Top 2 Percent Limited. Top 2 Percent Limited is the data controller and can be contacted at:
Coxsole Farm, Stelling Minnis, Canterbury, Kent, CT4 6AQ
colum.price@top2percent.co.uk
+44(0)1227 202 244
Purpose
The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Site of the following:
- The personal data we will collect;
- Use of collected data;
- Who has access to the data collected;
- The rights of Site users; and
- The Site's cookie policy.
GDPR
For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.
Data Protection Officer
Colum Price is the company data protection officer and is responsible for the implementation of this policy. If consultants have any questions about data protection in general, this policy or their obligations under it, they should direct them to Colum Price - contactable at colum.price@top2percent.co.uk.
Consent
By using our Site users agree that they consent to: 1. The conditions set out in this Privacy Policy.
Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.
We rely on the following legal basis to collect and process the personal data of users in the EU:
- Processing of user personal data is necessary for us to take, at the request of a user, steps before entering a contract or for the performance of a contract to which a user is a party. If a user does not provide the personal data necessary to perform a contract the consequences are as follows:
If you do not provide your personal information, we cannot contact you regarding any enquiry you make regarding our courses and consultancy services.
Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.
Data Collected Automatically
When you visit and use our Site, we may automatically collect and store the following information:
- IP address;
- Location;
- Clicked links;
- Content viewed; and
- Website visitor data via Google Analytics.
Data Collected in a Non-Automatic Way
We may also collect the following data when you perform certain functions on our Site:
- First and last name;
- Company name
- Address
- Email address; and
- Phone number.
This data may be collected using the following methods:
- Website contact form
- Telephone enquiry
- Enquiry originating from social media channels such as Linked In.
How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.
The data we collect automatically is used for the following purposes:
1. For website visitor traffic statistics to help us understand our marketing.
The data we collect when the user performs certain functions may be used for the following purposes:
- Communication.
Who We Share Personal Data With
Employees
We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.
Other Disclosures
We will not sell or share your data with other third parties, except in the following cases;
- If the law requires it;
2. If it is required for any legal proceeding;
3. To prove or protect our legal rights; and
4. To buyers or potential buyers of this company in the event that we seek to sell the company.
If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.
How Long We Store Personal Data
User data will be stored until the purpose the data was collected for has been achieved.
You will be notified if your data is kept for longer than this period.
How We Protect Your Personal Data
In order to protect your security, we use the strongest available browser encryption and store all of our data on servers in secure facilities. All data is only accessible to our employees.
While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.
Your Rights as a User
Under the GDPR, you have the following rights:
- Right to be informed;
- Right of access;
- Right to rectification;
- Right to erasure;
- Right to restrict processing;
- Right to data portability; and
- Right to object.
Children
We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our privacy officer.
Our complete Data Protection Policy:
Top2% is committed to all aspects of data protection and takes seriously its duties and the duties of its consultants, under the Data Protection Act 1998. This policy sets out how Top2% deals with personal data, including personnel information and data subject access requests, and consultants’ obligations in relation to personal data. This personal data may be used for a number of purposes, including without limitation, assessing the suitability of the consultant for assignments; providing details of the consultant to clients; dealing with requests and enquiries; maintaining records; assisting with police investigations and/or enquiries; and/or complying with statutory and regulatory obligations.
Click to download the full policy document here.
How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our privacy officer here:
Colum Price
Coxsole Farm, Stelling Minnis, Canterbury, Kent, CT4 6AQ
colum.price@top2percent.co.uk
+44(0)1227 202 244
Cookie Policy
A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this maydecrease the quality of your user experience.
We use the following types of cookies on our Site:
- Analytical cookies
Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc; and - Third-Party Cookies
Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:
a. Google Analytics to monitor volume of traffic
b. Google Console to analyse page performance and keywords.
Modifications
This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.
Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner's Office in the UK.
Contact Information
If you have any questions, concerns or complaints, you can contact our Data Protection and Privacy Officer, Colum Price, at:
Colum Price
Coxsole Farm, Stelling Minnis, Canterbury, Kent, CT4 6AQ
colum.price@top2percent.co.uk
+44(0)1227 202 244