At Refreshing Horizons Limited, we respect your privacy and are committed to protecting your personal information. This policy explains how we collect information, what we do with it and what controls you have over your personal information when using our website www.refreshinghorizons.com.
We take our duty to process your personal information very seriously.
We may change this document from time to time to reflect the latest view of what we do with your information. Please check back frequently; you will be able to see if changes have been made by the date it was last updated at the end of the document.
Refer to the sections below for more details on how and why we use your personal information:
When you are browsing our website we have cookies in place to provide information on how you navigate the site and the pages you visit, so we can improve the content. You will be given the option to consent to these cookies or not when you visit the website.
Social Media Icons
On our website are links to our various social media pages. When you click on one of these links, you will be redirected to the relevant platform. Please be aware that these platforms have their own privacy rules in place, to find out more you may read their privacy policies.
Booking an initial discussion
When you click a link to book an initial discussion with Refreshing Horizons, you are redirected to our scheduling facility. This will allow you to choose a date and time which meets your requirements for the initial conversation. Our lawful basis for this is contract. Once you have booked an appointment, you will be sent email or text reminders about the appointment. Our lawful basis under data protection legislation for providing you with reminders is legitimate interests.
When you subscribe to the Refreshing Horizons Newsletter
When subscribing to the Refreshing Horizons newsletter, we ask for your name and email address. This allows us to personalise our communications with you. You will remain on the mailing list until you withdraw your consent by unsubscribing. You can unsubscribe at any time, either by using the unsubscribe option in any of our newsletters or by emailing firstname.lastname@example.org. We use a third party provider, Mailerlite, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. Our lawful basis for this under data protection legislation is consent.
When you become a client
When you become a client you will be asked to provide information in order for Refreshing Horizons to be able to offer you the best care and solutions for you. Some of the information you provide is considered Special Category or sensitive information under data protection legislation and we will seek your explicit consent in order to be able to retain this information.
When you become a client we may send you appointment reminders via text or email. Our lawful basis for data protection purposes is legitimate interests.
We may also send you information about other goods or services which may be of interest to you. You have the right to unsubscribe from these communications at any time. Our lawful basis for data protection purposes is legitimate interests.
When you contact us via email
When you make an enquiry via email or the contact form, the information in the email will only be used to respond to your request or question. We try to respond to email queries as promptly as possible but it can take the team up to 48 hours to respond to email queries especially at busy times, so please be patient with us. Our lawful basis for this under data protection legislation is consent.
When you take part in online research or surveys
Occasionally, we ask for feedback on your interaction with the website, our services and your customer experience. We will use a secure online platform to gather your responses which may include your name and contact details in case we need to contact you to follow up on your answers. Our lawful basis for this under data protection legislation is consent.
Facebook Adverts (Sponsored Posts)
Occasionally we run Facebook Adverts to promote the visibility of our services. When you click on our advert you are consenting to finding out more about us. Our Facebook Adverts use the Facebook Pixel Service of Facebook Inc. 1601 S.California Avenue, Palo Alto, CA94304. USA (Facebook). This tool allows us to find out more about the actions of users after they are redirected to our website. It also allows us to measure the efficiency of our Facebook adverts for statistical and market research purposes. Using this information allows us to improve our advertising for a better experience to our users and provide you with further advertising on Facebook and the use of Custom Audiences. You can find out more about this and withdraw your consent here: https://www.facebook.com/ads/website_custom_audiences/
Links to other websites
In order to be able to provide you with additional services such as if we run an event you wish to attend. Where we have a contract in place for the services, we take steps to ensure that your personal information is secure and only used in the way we prescribe.
For other third-party websites, we will make clear that you are being redirected.
We suggest that you review the privacy policies for any third-party websites you visit as we cannot accept any liability for the way they manage your personal information.
The information we need
Refreshing Horizons is what’s known as the ‘data controller’ of the personal information you provide to us. Your relationship with us determines how much information we collect from you. We will only ever collect the information needed to provide you with advice and services.
We will be very clear with you about the reason for collecting information and how we intend to use, share and store that information at the point we collect it.
Collecting your personal information
We collect personal information about you through a variety of different methods including when you:
- Sign up to our mailing list
- Ask for more information
- Send us correspondence via email
- Purchase products or services from us
- Provide us with feedback
The Refreshing Horizons website is not intended for anyone under 16. If you are under 16, please ensure you obtain your parent/guardian’s consent before sending any personal information to Refreshing Horizons.
Where is your information stored?
Wherever possible, all the personal information we process is processed within the UK or the European Economic Area (EEA). Some of our third-party service providers, for example PayPal, are based outside the EEA so their processing of your personal information will involve a transfer outside the EEA.
Whenever we transfer your personal information outside of the EEA, we do our best to make sure a similar degree of security of personal information by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission; 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 information the same protection it has in Europe; or
If you fail to provide the information requested
If you fail to provide the information requested where we need the personal information for either legal or accounting purposes or to fulfil our contract with you, we may need to cancel your services. Before cancelling your services, we will notify you that you are required to provide the missing information and give you a further reminder before cancellation.
Sharing your information
We only share your information where it is necessary to provide you with a service e.g. Delivery company, accountants, payment providers, etc or where we are obliged to by law, for purposes of national security, taxation and criminal investigations and in the following instances:
- If you have agreed that we may do so
- If we sell the business – the new owner may obtain subscriber and past booker information. This information would only be used for the same purposes for which it was originally obtained.
- If we run an event in partnership with other named organisations, your details may need to be shared. We will be very clear what will happen to your personal information when you register.
And we will never sell or rent your personal information to other organisations.
Retaining your information
We hold your information only as long as necessary for each reason that we use it. For example, your email address on our subscriber list will be held whilst you are a subscriber. If you purchase from us, we will retain that information for up to seven years for accounting purposes. During the retention period we ensure the security and integrity of the information.
What are your rights?
You have a number of rights about how the personal information you provide can be used. These are:
- Transparency over how we use your personal information (right to be informed).
- The ability to request a copy of the information we hold about you, which will be provided to you within one month (right of access).
- Update or amend the information we hold about you if it is wrong (right of rectification).
- Ask us to stop using your information (right to restrict processing).
- Ask us to remove your personal information from our records (right to be ‘forgotten’).
- Object to the processing of your information for marketing purposes (right to object).
- Obtain and reuse your personal information for your own purposes (right to data portability).
- Not be subject to a decision when it is based on automated processing (automated decision making and profiling).
If you wish to raise a complaint about how we have handled your personal information, you can contact us, and we will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal information in accordance with the law, you may complain to the Information Commissioner’s Office (ICO).
If you would like to know more about your rights under data protection law, you can find out more at the Information Commissioners Office website.
How to contact us
Refreshing Horizons Limited is registered with the Information Commissioner’s Office as a Data Controller. Our registration number is ZA017284
Trading as Refreshing Horizons Limited registered in England and Wales. Reg. No. 7090368 whose registered office is: 1 Sycamore Close, Sibford Gower, Banbury, Oxfordshire OX15 5SB
Last updated: April 2021