PRIVACY POLICY

1.   INTRODUCTION

1.1     We are committed to safeguarding the privacy of our website visitors and service users.

 

1.2     This policy applies where we are acting as a data controller with respect to the personal data of our website visitors             and service users (www.anjli.com); in other words, where we determine the purposes and means of the processing of             that personal data. It is effective from August 3, 2018.

 

1.3     We use both essential and non-essential cookies on our website.  Insofar as those cookies are not strictly necessary for           the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our                 website. 

 

1.4     Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy             controls, you can specify whether you consent to data analytics. You can access the privacy controls via:

            (a)       aboutcookies.org

            (b)       opt out / do not track

1.5     Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy             controls, you can specify whether you consent to blog subscriptions. You can request to be removed at any time by               emailing: privacy@anjli.com

1.6     In this policy, "we", "us" and "our" refer to Anjli Gheewala. For more information about us, see Section 13.

 

1.7     We do not sell your information to third parties. 

 

1.8     This website and our products and services are not intended for children and we do not knowingly collect data relating           to any person under the age of 18. Please do not submit any information to us if you are under the age of 18.

 

 

 

2.   HOW WE USE YOUR PERSONAL DATA

2.1     In this Section 2 we have set out:

            (a)      the general categories of personal data that we may process;

            (b)      in the case of personal data that we did not obtain directly from you, the source and specific categories of                          that data;

            (c)      the purposes for which we may process personal data; and

            (d)      the legal bases of the processing.

2.2     We may process data about your use of our website and services ("usage data"). The usage data may include                       your geographical location, browser type and version, operating system, referral source, length of visit, page                       views and website navigation paths, as well as information about the timing, frequency and pattern of your                         service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the             purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests,           namely monitoring and improving our website and services.

2.3     We may process your account data ("account data"). The account data may include your name, email address and any           information you include in your message. The source of the account data is you. The account data may be processed             for the purposes of operating our website, providing our services, ensuring the security of our website and services,               maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our                       legitimate interests, namely the proper administration of our website and business.

 

2.4     We may process your personal data that are provided in the course of the use of our services ("service data"). The                 service data may include billing information, contact details and contract. The source of the service data is you. The             service data may be processed for the purposes of operating our website, providing our services, ensuring the security           of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for             this processing our legitimate interests, namely the proper administration of our website and business.

 

2.5     We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry                 data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or             services to you. The legal basis for this processing is legitimate interests, namely responding to your enquiry. 

 

2.6     We may process information relating to our customer relationships, including customer contact information ("customer             relationship data"). The customer relationship data may include your name, your employer, your job title or role, your             contact details, and information contained in communications between us and you. The source of the customer                     relationship data is you. The customer relationship data may be processed for the purposes of managing our                       relationships with customers, communicating with customers, keeping records of those communications and promoting             our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper           management of our customer relationships.

 

2.7     We may process information relating to transactions, including purchases of goods and services, that you enter into               with us and/or through our website ("transaction data"). The transaction data may include your contact details, your               card details and the transaction details. The transaction data may be processed for the purpose of supplying the                   purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is           the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract             and our legitimate interests, namely the proper administration of our website and business. 

 

2.8     We may process information that you provide to us for the purpose of subscribing to our email notifications and/or               blogs ("notification data"). The notification data may be processed for the purposes of sending you the relevant                     notifications and/or blogs. The legal basis for this processing is consent.

2.9     We may process information contained in or relating to any communication that you send to us ("correspondence                   data"). The correspondence data may include the communication content and any relevant associated with the                     communication. Our website will generate relevant data associated with communications made using the website                 contact forms. The correspondence data may be processed for the purposes of communicating with you and record-               keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website           and business and communications with users.

 

2.10   We may process notes from the services we provide you. This data may include general notes from our sessions. The             source of this data is you. This data may be processed for supporting clients where appropriate and insurance                     purposes. The legal basis for this processing is our legitimate interests, namely managing our business risks and                   providing our services.

 

2.11   We may process any of your personal data identified in this policy where necessary for the establishment, exercise or             defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis           for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights             and the legal rights of others.

 

2.12   We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or             maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing             is our legitimate interests, namely the proper protection of our business against risks.

 

2.13   In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may               also process any of your personal data where such processing is necessary for compliance with a legal obligation to             which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

2.14   Please do not supply any other person's personal data to us, unless we prompt you to do so or unless you have been             asked to do so directly from the other person.

2.15   We do not intentionally collect what is known as Special Category Data (sensitive personal information) which includes           details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, sex           life, sexual orientation, information about your health, genetic and biometric data. If you intentionally or accidentally             share such data with us, you will be considered to have consented to our processing of that information. We will                   process this data lawfully. The legal basis for this processing is consent, namely for the purpose of supporting your                 needs appropriately when providing our services. The special category condition for processing such data is explicit             consent.

 

 

 

3.   PROVIDING YOUR PERSONAL DATA TO OTHERS

3.1     We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for             the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the               establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court             procedure.

 

3.2     In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data               where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to                 protect your vital interests or the vital interests of another natural person. We may also disclose your personal data                 where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court                       proceedings or in an administrative or out-of-court procedure.

 

 

4.   INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

 

4.1     In this Section 5, we provide information about the circumstances in which your personal data may be transferred to               countries outside the European Economic Area (EEA).

4.2     Our third-party providers have offices and facilities in the USA, Europe: including Lithuania, Germany Ukraine, Ireland,           and Israel. The European Commission has made an "adequacy decision" with respect to the data protection laws of               each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the             use of standard data protection clauses adopted or approved by the European Commission. 

 

4.3     All our providers based in the USA are self-certified against the EU-US Privacy Shield. The categories of providers that             we share data with for the purposes of our business services are related to hosting, email and cloud storage.

 

4.4     The hosting facilities for our website has servers all over the world including Europe and the US as well as back up               servers in multiple locations. If the Processing of the User Customer Data involves transfer of such data outside of the             European Economic Area (EEA) and the European data protection regulations apply to the transfers of such data, these           transfers will be conducted in compliance with all applicable data protection regulations.

 

4.5     You acknowledge that personal data that you submit for the publication through our website or services may be                     available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

 

4.6     The legal basis for sharing data with third parties is legitimate interest, namely to run our business efficiently.

 

 

 

5.   RETAINING AND DELETING PERSONAL DATA

5.1     This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply             with our legal obligations in relation to the retention and deletion of personal data.

 

5.2     Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that                   purpose or those purposes.

 

5.3     We will retain your personal data as follows:

             (a)     personal data category or categories will be retained for a minimum period of 3 months following initial                              enquiry, and for a maximum period of 6 years after the end of that financial year.

5.4     In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained.           In such cases, we will determine the period of retention based on the following criteria:

             (a)      the period of retention of personal data category will be determined based on legal obligation, ongoing                              relationships and service provision, industry practices, continued legal basis for processing (e.g. consent),                            business risks and industry practices. 

5.5     Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is                   necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or             the vital interests of another natural person.

 

 

 

6.   AMENDMENTS

6.1     We may update this policy from time to time by publishing a new version on our website.

 

6.2     You should check this page occasionally to ensure you are happy with any changes to this policy.

 

6.3     We will notify you of changes with a new effective data OR if there are significant changes to this policy we may                 notify you by posting a message on our website. 

 

 

7.   YOUR RIGHTS

7.1     In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are                   complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant               laws and guidance from the regulatory authorities for a full explanation of these rights.

 

7.2     Your principal rights under data protection law are:

             (a)      the right to access;

             (b)      the right to rectification;

             (c)      the right to erasure;

             (d)      the right to restrict processing;

             (e)      the right to object to processing;

             (f)       the right to data portability;

             (g)      the right to complain to a supervisory authority; and

             (h)      the right to withdraw consent.

7.3     You have the right to confirmation as to whether or not we process your personal data and, where we do, access to               the personal data, together with certain additional information. That additional information includes details of the                 purposes of the processing, the categories of personal data concerned and the recipients of the personal data.                     Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The             first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access             your personal data by emailing us at privacy@anjli.com

 

7.4     You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of             the processing, to have any incomplete personal data about you completed.

 

7.5     In some circumstances you have the right to the erasure of your personal data without undue delay. Those                           circumstances include: the personal data are no longer necessary in relation to the purposes for which they were                   collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing                 under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal           data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions               include where processing is necessary: for exercising the right of freedom of expression and information; for                         compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

 

7.6     In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you           contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the                 personal data for the purposes of our processing, but you require personal data for the establishment, exercise or                 defence of legal claims; and you have objected to processing, pending the verification of that objection. Where                   processing has been restricted on this basis, we may continue to store your personal data. However, we will only                 otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of           the rights of another natural or legal person; or for reasons of important public interest.

 

7.7     You have the right to object to our processing of your personal data on grounds relating to your particular situation, but           only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a               task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the                 legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the                 personal information unless we can demonstrate compelling legitimate grounds for the processing which override your             interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

 

7.8     You have the right to object to our processing of your personal data for direct marketing purposes (including profiling             for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this                 purpose.

          

7.9     To the extent that the legal basis for our processing of your personal data is:

             (a)      consent; or

             (b)      that the processing is necessary for the performance of a contract to which you are party or in order to take                         steps at your request prior to entering into a contract, and such processing is carried out by automated                               means, you have the right to receive your personal data from us in a structured, commonly used and machine-                       readable format. However, this right does not apply where it would adversely affect the rights and freedoms                         of others.

 

7.10   If you consider that our processing of your personal information infringes data protection laws, you have a legal right             to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member               state of your habitual residence, your place of work or the place of the alleged infringement. The supervisory authority           for the UK is the Information Commissioner's Office.

 

7.11   To the extent that the legal basis for our processing of your personal information is consent, you have the right to                   withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

 

7.12   You may exercise any of your rights in relation to your personal data by emailing us at:privacy@anjli.com

 

 

8.   ABOUT COOKIES

 

8.1     A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web                     browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a               page from the server.

 

8.2     Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser               and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on             the other hand, will expire at the end of the user session, when the web browser is closed.

 

8.3     Cookies do not typically contain any information that personally identifies a user, but personal information that we store           about you may be linked to the information stored in and obtained from cookies.

 

 

 

9.      COOKIES THAT WE USE

9.1     We use cookies for the following purposes:

             (a)      authentication - we use cookies to identify you when you visit our website and as you navigate our website.

             (b)      analysis - we use cookies to help us to analyse the use and performance of our website and services

             (c)      cookie consent - we use cookies (to store your preferences in relation to the use of cookies more generally)

 

 

 

10.    COOKIES USED BY OUR SERVICE PROVIDERS 

10.1   Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

             (a)      Session (Transient) cookies: These cookies are erased when you close your browser, and do not collect                                information from your computer. They typically store information in the form of a session identification that                            does not personally identify the user.

             (b)      Persistent (Permanent and Stored) cookies: These cookies are store on your hard drive until they expire (i.e.                            they are based on a set expiration date) or until you delet them. These cookies are used to collect identifying                        information about the user, such as Web surfing behaviour.

10.2     We use a simple website analytics service which measures the traffic and visitors' general details of the customers'                 websites. Collecting these statistics, a website can make their visitors' experience better (e.g. which pages they visit             and when, where they are approximately located, where does a user land first or if they are coming from a specific

            referral). As a website owner using Visitor Analytics, we are using cookies to collect data about visitors' device type               and screen size, approximate location, browser, OS, page visits, bounce rate, conversions and popular content on               the website. All this data is pseudonymised and Visitor Analytics will never use the collected data to identify                         individual users or to match it with additional information on an individual user. Each visitor has control over the                   cookies placement.

 

10.3     You can control and/or delete cookies as you wish by checking your browser settings on each device - for details,                 see aboutcookies.org OR opt out/do not track from analytics.

 

 

 

11.   MANAGING COOKIES

11.1      Most browsers allow you to refuse to accept cookies and to delete cookies. The method for doing so vary from                      browser to browser, and from version to version. You can however obtain up-to-date information about blocking                    and deleting cookies via these links:

                (a)      https://support.google.com/chrome/answer/95647?hl=en (Chrome);

                (b)      https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

                (c)      http://www.opera.com/help/tutorials/security/cookies/ (Opera); 

                (d)      https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies 

                         (Internet Explorer);

                (e)      https://support.apple.com/kb/PH21411 (Safari); and

                (f)       https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

 

11.2      Blocking all cookies will have a negative impact upon the usability of many websites.

 

11.3      If you block cookies, you will not be able to use all the features on our website.

 

 

 

12.   OUR DETAILS

12.1      This website is owned and operated by Anjli Gheewala.

12.2      You can contact us by:

                (a)     using our website contact form

                (b)     by email, using the email address published on our website from time to time: privacy@anjli.com.