PRIVACY POLICY

"We", "our" or "us" means SHY Lifestyle, a company registered in England with registration number 11206687 and whose registered office is at 3rd Floor, 91-93 Buckingham Palace Road, London, SW1W 0RP. “Our website” means www.shylifestyle.com.

 

This privacy policy has been prepared in accordance with the EU General Data Protection Regulation (GDPR). 

 

This privacy policy sets out how we use your personal data, when we collect it from you or when you provide it to us when you: use our website, work at one of the organisations that uses our platform to source industry experts or are an industry expert that uses our platform.

 

Please contact us if you have any questions about this privacy policy or the personal data we hold about you: by phone on +44 (0) 20 3915 3834, by email: request@shylifestyle.com, or by writing to us at: SHY Lifestyle, 3rd Floor, 91-93 Buckingham Palace Road, London, SW1W 0RP.

 

Please read the following about how we will use your personal data:

·      Information we collect when you use our website and how we use that information

·      Our legal basis for using the information we collect when you use our website

·      Information we collect when you are an individual within one of our client organisations who uses our platform and how we use that information

·      Our legal basis for using the information we collect when you are an individual at one of our client organisations

·      Information we collect from you when you register or your organisation registers as an expert on our platform and how we use that information

·      Our legal basis for using the information we collect when you register or your organisation registers as an expert

·      How we use your personal data for marketing

·      Our legal basis for sending you marketing

·      How long we will keep your personal data

·      Sharing your personal data

·      Transfer of personal data outside the European Economic Area

·      Your rights over your personal data

·      Third party links on our website

·      Cookies

·      Changes to our privacy policy

·      How to contact us

 

1          INFORMATION WE COLLECT WHEN YOU USE OUR WEBSITE AND HOW WE USE THAT INFORMATION

 

We will collect and use the following personal data about you:

 

·      Information you give us. This is information about you that you give us by filling in forms on our website which will be your name, address, email address and phone number.

 

We will use this information to respond to the query that you have sent to us through the form on our website.

 

·       Information we collect about you. We collect information about you through our website cookies. For more information on the cookies we are using, please see the Cookies section [http://www.shyaviation.com/cookie-policy/] below. We will collect your IP address, and information relating to your visits to our website, for instance which pages you visited, how long you spent on them, the dates and times you visited.

 

We will use this information to understand how our website is being used and to improve your experience in using our website.

 

1             OUR LEGAL BASIS FOR USING THE INFORMATION WE COLLECT WHEN YOU USE OUR WEBSITE

Under data protection law we must have a legal basis to use your personal data. We have set these out below.

·         Information you give us. Where you fill in a form on our website, the legal basis for this use is that it is in our legitimate interests as a business to be able to contact you and to effectively respond to the query or request you have made through our website. We have considered our legitimate interests carefully and have balanced them against your rights under data protection law. We consider that this is a proportionate use of your personal data because we will only use the information, we get from you to respond to your query or request. 

 

·         Information we collect about you. Our legal basis for using the personal data we collect when you use our website is that it is in our legitimate interests to understand how our website is being used and to be able to improve the user experience of our website. We have considered our legitimate interests carefully and have balanced them against your rights under data protection law. We consider that this is a proportionate use of your personal data because we collect minimal information about you and will only use it to review our website use and help improve our website.

 

2             INFORMATION WE COLLECT WHEN YOU ARE AN INDIVIDUAL WITHIN ONE OF OUR CLIENT ORGANISATIONS WHO USES OUR PLATFORM AND HOW WE USE THAT INFORMATION

We will collect and use the following data personal data about you:

 

·         Information you give us. When your organisation signs up to use our platform and you are the individual within your organisation who is the platform user, we will collect user account data, which will be your name, address, email address, photo, job title, phone number and your organisation’s financial and payment information.

 

We will use this information to administer and manage your organisation’s user account, to contact you about the contract we have with your organisation, to facilitate payment, to contact you in relation to opportunities on the platform, and to deal with any queries you have about our services.

 

·         Information we collect about you. We collect information about your use of our platform through third parties Google Analytics, FullStory, LogRocket, Hubspot and Intercom relating to the engagements you enter into through our platform and the experts you work with. We will also collect your location data if you enable this in your security settings on the platform.

 

We will use this information to understand how our customers use our platform, in order to improve it, and also to offer you location-specific information (for example information about experts in your location who can help).

 

3             OUR LEGAL BASIS FOR USING THE INFORMATION WE COLLECT WHEN YOU ARE AN INDIVIDUAL AT ONE OF OUR CLIENT ORGANISATIONS

·         Information you give us where your organisation that is our client is a partnership and therefore you are treated as an individual for the purposes of data protection law. Our legal basis for using your personal data for the reasons explained above is that it is necessary for taking steps prior to entering into a contract with you and it is necessary for performing our contract with you for the provision of our platform. Failure to provide your personal data may mean we are unable to fulfil the services you order or deal with your queries.

 

·         Information you give us where your organisation that is our client is a company. Our legal basis for using your personal data as the individual within our client organisation for the reasons explained above is that it is in our legitimate interests in carrying out the contract, we have with your organisation to provide your organisation with our platform. We have considered our legitimate interests carefully and have balanced them against your rights under data protection law. We consider that this is a proportionate use of your personal data because it is in your reasonable expectations that we would need to contact you for the purposes of your organisation’s account with us and we only use your business contact details for matters which relate directly to our relationship with the organisation you work for.

 

·         Information we collect about you. Our legal basis for using the personal data we collect when you use our platform is that it is in our legitimate interests to understand how our platform is being used and to be able to improve the user experience of our platform. We have considered our legitimate interests carefully and have balanced them against your rights under data protection law. We consider that this is a proportionate use of your personal data because we will only use it to review our platform use and help improve our platform.

 

4             INFORMATION WE COLLECT FROM YOU WHEN YOU REGISTER OR YOUR ORGANISATION REGISTERS AS AN EXPERT ON OUR PLATFORM AND HOW WE USE THAT INFORMATION

We will collect and use the following personal data about you:

 

·         Information you give us. Where you register or your organisation registers as an expert on our platform, we will collect profile data of expert consultants which will be your name, photo, job title, career history, hourly rates, address, email address, phone number, and financial information.

 

We will use this information to administer and manage your expert profile, to perform identity checks, to facilitate payment, to provide you with an online profile for clients to engage your services, to represent your experience on the platform, to provide professional indemnity insurance, to contact you in relation to opportunities on the platform, to notify our clients that you are an expert on our platform so that they can contact you about their relevant projects, and to deal with any queries you have about our services. We will also use this information to promote and present experts to our clients via investor material, client proposals, online/digital marketing and direct introductions and to promote our company and its services. Where you confirm that you are happy for us to do so, we will use a summary of your expert profile (such as your name, photo, job title, previous/current companies, and hourly/daily rates) in our marketing documentation and client proposals.

 

·         Information we collect about you. We collect information about your use of our platform through third parties Google Analytics, FullStory, LogRocket, Hubspot and Intercom relating to the engagements you enter into through our platform and the organisations you work with. We will also collect your location data if you enable this in your security settings on the platform.

 

We will use this information to understand how our experts use our platform, in order to improve it, and also to offer you location-specific information (for example information about opportunities and projects in your location that you may wish to take part in).

 

5             OUR LEGAL BASIS FOR USING THE INFORMATION WE COLLECT WHEN YOU REGISTER OR YOUR ORGANISATION REGISTERS AS AN EXPERT

·         Information you give us where you are an individual that registers as an expert on our platform. Our legal basis for using your personal data for the reasons explained above (other than including your expert profile in our marketing and client proposals or presenting you to clients via the platform) is that it is necessary for taking steps prior to entering into a contract with you and it is necessary for performing our contract with you for the provision of our platform. Failure to provide this personal data may mean we are unable to fulfil the services you order or deal with your queries.

 

Our legal basis for using your personal data as explained above to include your expert profile in our marketing and client proposals or presenting you to clients via the platform is that you have consented to us using your personal data in these ways. You can change your mind about this at any time by contacting us by email:fly@shyaviation.com, by phone +44 (0) 20 8616 8821 or by writing to us at: SHY Lifestyle, 3rd Floor, 91-93 Buckingham Palace Road, London, SW1W 0RP.

 

·         Information you give us where you are an individual within an organisation that registers as an expert on our platform. Our legal basis for using your personal data as the individual within an expert organisation for the reasons explained above is that it is in our legitimate interests in carrying out the contract, we have with your organisation to provide your organisation with our platform. We have considered our legitimate interests carefully and have balanced them against your rights under data protection law. We consider that this is a proportionate use of your personal data because it is in your reasonable expectations that we would need to contact you for the purposes of your organisation’s account with us and we only use your business contact details for matters which relate directly to our relationship with the organisation you work for.

 

Our legal basis for using your personal data as explained above to include your expert profile in our marketing and client proposals or presenting you to clients via the platform is that you have consented to us using your personal data in these ways. You can change your mind about this at any time by contacting us by email requests@shylifestyle.com, by phone +44 (0) 20 8616 8821 or by writing to us at: SHY Lifestyle, 3rd Floor, 91-93 Buckingham Palace Road, London, SW1W 0RP.

 

6             HOW WE USE YOUR PERSONAL DATA FOR MARKETING

·         Information you give us. When we collect personal data from you through our website, when you or your organisation registers as a client on our platform or when you or your organisation registers as an expert on our platform, we will collect your contact details and ask you to tick a box to say if you are happy to receive marketing from us.

 

If you agree to it, we will use your personal data to send you marketing in the ways you have agreed that we can contact you. We will send you marketing about our products and services, offers that we have on, competitions that you can take part in, and events that may interest you.

 

7             OUR LEGAL BASIS FOR SENDING YOU MARKETING

Our legal basis for sending you marketing is that you have consented to receiving marketing from us.

You can change your mind about receiving marketing from us at any time by contacting us by email:requests@shylifestyle.com, by phone +44 (0) 20 8616 8821 or by writing to us at: SHY Lifestyle, 3rd Floor, 91-93 Buckingham Palace Road, London, SW1W 0RP, or by following the unsubscribe links in our marketing emails.

8             HOW LONG WE WILL KEEP YOUR PERSONAL DATA

We will not keep your personal data for longer than we need it for the purposes we have explained in this privacy policy.

We will keep the personal data that you provide and that we collect or receive in relation to your account when you or your organisation registers as a client or expert on our platform for six years from the date our contract with you ends.

We will keep the personal data you provide or we collect or receive in relation to queries you make about our platform but where you do not end up registering for our platform at that point for two years after the end of our communications with you, in case you get back in touch with us at a later date for further information, so we can refer back to our previous discussions with you.

Where we have collected your personal data for marketing, we will keep it for two years from the date you give your consent to receiving marketing from us, or until you withdraw your consent to receiving marketing from us.

 

If a dispute arises between us, we will continue to retain your personal data for the purposes of responding to and dealing with any such dispute.

9             TRANSFER of personal data OUTSIDE THE European Economic Area

We store your personal data in the United Kingdom or in countries within the European Economic Area.

If we do transfer your personal data outside the EEA, we would only do so where we have a legal basis for doing so and where we ensure that your personal data is protected to the same standard as it would be protected in the UK. We would do this by entering into data sharing agreements with the recipients of your personal data based outside the EEA which comply with the EU Commission’s standard clauses for the transfer of personal data outside the EEA.

Please contact us for further information as to the transfer of your personal data outside the EEA, and if we are doing so on the basis of the EU’s standard clauses, you can ask us for a copy of those clauses: by email: requests@shylifestyle.com, by phone +44 (0) 20 8616 8821 or by writing to us at: SHY Lifestyle, 3rd Floor, 91-93 Buckingham Palace Road, London, SW1W 0RP.

YOUR RIGHTS OVER YOUR PERSONAL DATA

The law gives you certain rights over your personal data that we hold:

·                     You have a right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK authority for data protection issues (www.ico.org.uk).

·                     You have a right to ask us what personal data we hold about you and to have a copy of the personal data that we hold about you.

·                     You have a right to request that we correct any errors in your personal data.

·                     You have a right to ask us to delete your personal data where: (I) we do not need your personal data anymore; (ii) you have asked us to review and explain our legitimate interests to you and we do not actually have a valid legitimate interest to do what we are doing; (iii) our use of your personal data is illegal; (iv) we have to delete your personal data to comply with our legal obligations.

·                     Where (I) we have your personal data on the basis of your consent or because we need it to perform our contract with you; (ii) you provided your personal data to us; and (iii) we process your personal data by automated means, you have the right to ask us to give you a copy of your personal data in a commonly used, electronic format.

·                     You have the right to ask us to review and explain our legitimate interests to you and to object to our legitimate interests.

·                     Where our use of your personal data is based on your consent, you have the right to withdraw that consent at any time.

·                     You have the right to ask us to restrict our uses of your personal data where: (I) you do not think the personal data we have about you is correct, so that we can check if it is correct; (ii) what we are doing with your personal data is illegal but you would rather we stop using your personal data rather than delete it; (iii) we do not need your personal data anymore, but you need us to keep it so that you can exercise any legal rights; and/or (iv) you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing.

 

If you would like to exercise any of these rights, please contact us by email: requests@shylifestyle.com, by phone +44 (0) 20 8616 8821 or by writing to us at: SHY Lifestyle, 3rd Floor, 91-93 Buckingham Palace Road, London, SW1W 0RP.

THIRD PARTY LINKS ON OUR WEBSITE

Our website may include links to third party websites (for example LinkedIn), plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

10            COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

·         Necessary cookies. These are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log into secure areas of our website or session tracking.

·         Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.

·         Functionality cookies. These are used to recognise you when you return to the website. This enables us to personalise our content for you, greet you by name and remember your preferences.

·         Targeting cookies. These cookies record your visit to the website, the pages you have visited and the links you have followed. We will use this information to make the website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website and use the platform, and your user experience may be affected.

11            CHANGES TO OUR PRIVACY POLICY

We keep our privacy policy under regular review. Any changes we make in the future will be posted on this page. If we make significant changes in the way we treat your personal information, or to the policy, we will make that clear on our website, or by some other means such as email, so that you are able to review the changes before you continue to use our website.

12            HOW TO CONTACT US

Please contact us if you have any questions about this privacy policy or the personal data, we hold about you:

By phone: +44 (0) 20 3915 3834

By email: requests@shylifestyle.com,

Write to us at our address: SHY Lifestyle, 3rd Floor, 91-93 Buckingham Palace Road, London, SW1W 0RP.