PRIVACY POLICY MEANINGFUL VISION LTD

1. Meaningfulvision.com; Meaningfulvision.co.uk (the Site) are operated by Meaningful Vision LTD (we, us, our), a company incorporated in England and Wales under company number 13589397. Our registered office address is C/O Schoolgate Accounting Services The Old Town Hall, 4 Queens Road, Wimbledon, England, SW19 8YB.
2. We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the United Kingdom General Data Protection Regulation (the UK GDPR) and any other applicable UK legislation (together, Data Protection Law).
3. When you interact with us or use the Site, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy policy explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.
4. This policy was last updated on the date shown at the top. We may change this policy at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made.

• “I”, “our”, “us”, or “we” refers to Meaningful Vision LTD;
• “you”, “the user” refer to the person(s) using our website;
• PECR means Privacy & Electronic Communications Regulation;
• ICO means Information Commissioner’s Office;
• Cookies mean small files stored on a users’ computer or device; and
• DPO means a data protection officer.

1. Lawfulness, fairness and transparency;
2. Purpose limitation;
3. Data minimisation;
4. Accuracy;
5. Storage limitation;
6. Integrity and confidence; and
7. Accountability.

1. If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
   Full name of legal entity: Meaningful Vision LTD
   Email address: info@meaningfulvision.co.uk
   Postal address: C/O Schoolgate Accounting Services The Old Town Hall, 4 Queens Road, Wimbledon, England, SW19 8YB
2. You have the right to make a complaint at any time to the ICO, the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1. We collect, store and use the types of below personal data set. Please also refer to the table at the end of this policy.
2. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
3. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
   1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
   2. Contact Data includes billing address, delivery address, email address and telephone numbers;
   3. Financial Data includes bank account and payment card details;
   4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;
   5. Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
   6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
   7. Usage Data includes information about how you use our website, products and services; and
   8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
   9. We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
   10. We do not collect any special categories of personal data about you (this 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). Nor do we collect any information about criminal convictions and offences.

1. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

1. We use different methods to collect data from and about you including through:
   1. Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
   • apply for our products or services;
   • create an account on our website;
   • subscribe to our service or publications;
   • request marketing to be sent to you;
   • enter a competition, promotion or survey; or
   • give us feedback or contact us.
   2. Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
   3. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below.
   4. Identity and contact data from data brokers or aggregators.
   5. Identity and contact data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

1. We will use your personal data for the purposes set out in the table at the end of this policy. We are exempt from registration in the ICO Data Protection Register because we only process data for staff administration and for advertising, marketing and public relations.
   Under the UK GDPR we control and / or process any personal information about you electronically only when you consent for us to use your data for these purposes set out in the table at the end of this policy.
2. We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists.
3. If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.

1. When we share and disclose your personal data, we do so in accordance with Data Protection Law. We may share certain personal data for the purposes set out in the table at the end of this policy.
2. We may share your personal information with third parties, such as lawyers, banks, government officials, HMRC and other governmental authorities.
3. In addition, we may 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 policy.
4. 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.
5. We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so we will make sure that it does not identify you.

1. This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other sites which you choose to access from this Site. We encourage you to review the privacy policies of those other sites, so you can understand how they collect, use and share your personal information.

1. We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.
2. Depending on the reason we have your personal data, you have a right to:
   1. Access the personal information we hold about you (commonly known as subject access): this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
   2. Request that we correct or complete personal information we hold about you that is inaccurate or incomplete: 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;
   3. Request that we erase your personal information in some circumstances: 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;
   4. 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;
   5. 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:
      • If you want us to establish the data’s accuracy;
      • Where our use of the data is unlawful but you do not want us to erase it;
      • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and
      • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
   6. Request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services: 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; and
   7. Where we have asked for your consent to process your data, to withdraw this consent: 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.
3. These rights are limited in some situations under Data Protection Law – for example, where we can demonstrate that we are under a legal obligation to process your data.
4. If you wish to exercise any of these rights, please contact us using the details in paragraph 4 above.

1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
2. 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, regulatory, tax, accounting or other requirements.

1. We process your personal data in accordance with the following principles:
   1. we process your personal data lawfully, fairly and in a transparent way;
   2. we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;
   3. we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;
   4. we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
   5. we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing save for circumstances referred to in paragraph 12.1; and
   6. we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.
2. When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data.
3. Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.

1. We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this policy sets out the lawful basis we rely on for each type of data we process.
2. We will choose one of the lawful bases in the UK GDPR to justify how we use your personal data. These are:
   1. Consent: You have given consent to the processing of your personal data for one or more specific purposes.
   2. Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.
   3. Legal obligation: We need to process your personal data to comply with a legal obligation.
   4. Vital interests: The processing is necessary to protect the vital interests of you or another person.
   5. Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.
   6. Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.

1. 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
2. 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.
3. 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.

1. We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the UK GDPR compliance requirement.

1. Under the UK GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the in the table at the end of this policy.
2. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third-party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
3. Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
4. Any email marketing messages we send are in accordance with the UK GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences.

1. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
2. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of our interaction with you.

1. We do not transfer your personal data outside the UK.

1. 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 could refuse to comply with your request in these circumstances.

1. 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.

1. We try to respond to all legitimate requests within one month. Occasionally it could 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.

TABLE OF PERSONAL INFORMATION WE USE

The table below sets out detailed information about our purposes for processing, the basis for processing and the retention period for the personal data.