Privacy Policy

1) Our Commitment To Privacy
2) The Information We Collect
3) How We Use Information
4) Our Commitment To Data Security
5) Our Commitment To Children’s Privacy
6) How To Access Or Correct Your Information
7) Conversion Tracking
8) How To Contact Us

Our Commitment To Privacy

Your privacy is important to us. To better protect your privacy we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used. To make this notice easy to find, we make it available on our homepage and at every point where personally identifiable information may be requested.

The Information We Collect:

This notice applies to all information collected or submitted on this website. On some pages, you can order products, make requests, and register to receive materials. The types of personal information collected at these pages are:

• Name
• Email address

The Information We DON’T Collect:

• Credit/Debit Card Information
• Mailing Address

The Way We Use Information:

We use the information you provide about yourself when placing an order only to complete that order. We do not share this information with outside parties except to the extent necessary to complete that order.

We use the information you provide about someone else when placing an order only to ship the product and to confirm delivery. We do not share this information with outside parties except to the extent necessary to complete that order.

We use return email addresses to answer the email we receive. Such addresses are not used for any other purpose and are not shared with outside parties.

You can register with our website if you would like to receive valuable free information as well as updates on our new products and services. Information you submit on our website will not be used for this purpose unless you fill out the registration form.

We use non-identifying and aggregate information to better design our website and to share with advertisers. For example, we may tell an advertiser that X number of individuals visited a certain area on our website, or that Y number of men and Z number of women filled out our registration form, but we would not disclose anything that could be used to identify those individuals.

Finally, we never use or share the personally identifiable information provided to us online in ways unrelated to the ones described above without also providing you an opportunity to opt-out or otherwise prohibit such unrelated uses.

Our Commitment To Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

Our Commitment To Children’s Privacy:

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our website from those we actually know are under 13, and no part of our website is structured to attract anyone under 13.

How You Can Access Or Correct Your Information

You can access all your personally identifiable information that we collect online and maintain by sending us an email or visiting our Support Desk. We use this procedure to better safeguard your information.

You can correct factual errors in your personally identifiable information by sending us a request that credibly shows error.

To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.

Conversion Tracking

We work with third parties such as Twitter and Facebook to collect user data through our website for purposes of conversion tracking and serving ads targeted to users’ interests. If you want to miss out on these tailored special offers being shown to you on these social networks, you can opt out of some of those third parties’ interest-based advertising through the Do Not Track functionality in your web browser or using Twitter’s guide here.

How To Contact Us

Should you have other questions or concerns about these privacy policies, please contact us here.

Website Privacy Policy

How We Protect Your Privacy

This website privacy policy tells you how we collect, use, and protect your personal information. By visiting our website (ascensionodyssey.com), you accept and agree to the terms and conditions of this website privacy policy. In particular, you consent to our collection and use of your personal information as described in this website privacy policy.

Minors

We do not provide services or sell products to children. However, we may sell products to adults for use by children. Regardless of the intended end user of our products, only adults should purchase anything from our website. If a product we offer is legal only for adults to use or possess, no adult should purchase the product for illegal use or possession by a minor.

If you are less than 18 years old, you may use our website only with the permission, active involvement, and supervision of an adult parent or legal guardian. If you are a minor, please do not provide us or other website visitors with any personal information.

This Policy Is Part Of Our Terms And Conditions Of Use

Our website privacy policy is a part of, and subject to, our website’s Terms and Conditions of Use. You may view these terms and conditions on our website.

This Policy and Customer Agreements

If you are our customer, any customer agreement between us supersedes this policy to the extent there is any conflict with the terms and conditions of the customer agreement.

The type of information we collect from you and interest-based advertising.

Like most places on the Internet, simply by visiting our website you automatically tell us certain information. This includes basic information such as your IP address, when you visited, the website from where you came prior to visiting us, the website where you go when you leave our website, your computer’s operating system, and the type of web browser that you are using. Our website automatically records this basic information about you.

And like many other websites, we may use cookies, digital fingerprinting (e.g. device, machine, and Internet browser fingerprints), web beacons, click redirects, pixel tags, container tags, and similar technologies. In plain English, this means information that our website’s server transfers to your computer. This information can be used to track your session on our website and to customize our website content for you as an individual.

If you are using one of the common Internet Web browsers, you can set up your browser to either (a) let you know when you are being tracked by us or to (b) deny us tracking access to your computer or electronic mobile device. The manufacturer of the browser you use has instructions on how to modify tracking settings. You may find these instructions in the “Help” section of your browser or by contacting the browser’s manufacturer.

If you download or use mobile software applications (“Mobile Apps”) from our website, we may know your location. In addition, your smart phone, computer tablet, or other electronic device using our Mobile Apps may provide us information about the device, including its unique identifier, make and model, operating system, mobile network carrier, and your telephone number. Your mobile device may have the ability to disable location services as well as deny us access to other information described in this paragraph. To learn more, check your mobile device’s user manual and/or contact your mobile device’s manufacturer or service carrier.

We may also collect any data that you provide us by posting it at our website or by sending to us via email. You can always choose not to provide us with information. However, if you do withhold information, we may deny you access to some or all of our website’s services and features.

Some transactions between you and our website may involve payment by credit card, debit card, checks, money orders, and/or third party online payment services. In such transactions, we will collect information related to the transaction as part of the course of doing business with you, including your billing address, telephone number, and other information related to the transaction.

What We Do With Your Information

We use your information to operate our website’s business activities. For example, we may use this data to contact you about changes to our website, direct marketing (e.g. new products and services, special offers, etc.), resolve disputes, troubleshoot issues, and enforce our website’s terms and conditions.

If you download or use Mobile Apps from our website, the information we learn about you may be used by us to give you personalized content based upon your location and other data you share. If you do not want to share your location via Mobile Apps, check the instruction manual for your electronic device or contact your device’s manufacturer to see if you can turn off the locator feature.

As a general rule, we will not give your data to third parties without your permission. However, there are some important exceptions to this rule that are described in the following paragraphs.

We may, in our sole discretion, provide information about you to law enforcement or other government officials for purposes of fraud investigations, alleged intellectual property infringement, or any other suspected illegal activity or matters that may expose us to legal liability.

Some government intelligence agencies have the technological ability to access data from our website without our cooperation, knowledge, or consent. Even if we were to learn of such access, we may not be able to tell you because of national security laws. Please take this risk into account before supplying information to us or any other website owner.

Although we do not disclose individually identifiable information, we may disclose aggregate data about our website’s visitors to advertisers or other third parties for marketing and promotional purposes.

From time to time, we may use third party suppliers to provide services on our website. If a supplier wants to collect information about you, you will be notified. However, you will never be required to give information to a third party supplier. We restrict the way third party suppliers can use your information. They are not allowed to sell or give your information to others.

If we sell our website, we may transfer your information to the purchaser of the site. Upon completion of such a transfer, we will no longer possess or control the data received by the purchaser.

Do-Not-Track, Interest-Based Advertising, Remarketing, and Dynamic Ad Serving

Do-Not-Track

We try to honor any Do-Not-Track signals you send through your web browser when visiting our website. However, please read the following important information about “Interest-Based Advertising,” “Remarketing,” and “Dynamic Ad Serving” so that you understand the type of tracking that may be done by third party vendors when you visit our site and how you can opt out of such tracking.

Interest-Based Advertising

When you visit our website, you may view advertisements posted on the site by Google or other companies. These advertising companies may collect information about you while you are visiting this website and other websites. They may use this data to show you advertisements on this website and elsewhere on the Internet about products and services you might like.

This website does not collect the information or control the content of the advertisements that you will see. You may be able to opt out of such advertising.

If you are in the United States, you may opt out of some advertising via the Digital Advertising Alliance at http://www.aboutads.info/choices/

If you are in Canada, you may opt out of some advertising via the Digital Advertising Alliance of Canada at  http://youradchoices.ca/

If you are in the Europe Union or the United Kingdom, you may opt out of some advertising via the European Interactive Digital Advertising Alliance at  http://www.youronlinechoices.com/

To find out more about Google privacy policies and its DoubleClick DART cookie used to generate interest-based advertising, go to  https://policies.google.com/technologies/ads .

Protect My Choices

If you are using Internet Explorer, Mozilla Firefox, or Google Chrome browsers, you may wish to install the “Protect My Choices” browser extensions that are designed to help you protect your opt-out preferences. To learn more, go to http://www.aboutads.info/PMC.

Remarketing

This website may use a remarketing tag to advertise online. This means that Google and other third-party vendors may show our ads to you on sites across the Internet. These third-party vendors, including Google, may use cookies to serve ads to you based upon your past visits to our website.

If you would like to opt out of Google’s use of cookies, you can visit the company’s Ad Preferences Manager at https://adssettings.google.com/authenticated?hl=en.

In the alternative, you can opt out of the use of cookies by some third-party vendors by going to the Network Advertising Initiative’s opt-out page located at  https://optout.networkadvertising.org/?c=1 .

Dynamic Ad Serving

Our website may use Google’s Dynamic Ad Serving feature. To opt out of interest-based ads by Google, follow Google’s opt-out instructions located at  https://support.google.com/ads/answer/2662922?hl=en .

DoubleClick Remarketing Pixels

Our website may use DoubleClick’s remarketing pixels. If you would like to opt out of DoubleClick’s use of cookies, you can visit the DoubleClick opt-out page at https://adssettings.google.com/authenticated?hl=en.

Your use of this website without opting out means that you understand and agree to data collection to provide you with interest-based advertising.

User Names And Passwords

Your access to parts of our website may be protected by a user name and a password. Do not give your password to anyone. If you enter a section of our website that requires a password, you should log out when you leave. As a safety precaution, you should also close out of your web browser completely and re-open it before viewing other parts of the Internet.

Use Of Information And Unsolicited Commercial Email

If you obtain personally identifiable information about another website user, you are not allowed to disclose this information to anyone else without the consent of the user and our consent too. If you communicate with other website users via our website (or by other means), such third parties may have copies of your communications even if you delete your own copies of such communications on our website and your electronic devices.

We hate junk email (spam). Information you obtain from our website about us or other site users cannot be used by you or others to send unsolicited commercial email or to send unsolicited commercial communications via our website’s posting or other communication systems.

Your Voluntary Disclosure Of Information To Third Parties Who Are Not Our Suppliers

You may choose to provide personal information to website visitors or other third parties who are not our suppliers. Please use caution when doing so. The privacy policies and customs of these third parties determine what is done with your information.

Autoresponders

We may use autoresponders to communicate with you by email. To protect your privacy, we use a verified opt-in system for such communications and you can always opt-out of such communications using the links contained in each autoresponder message. If you have difficulties opting out, you may contact us by sending an email to Support[at]ascensionodyssey.com, or sending us mail to the address listed below.

Information Security

We try to keep your information secure. If we become aware of a data vulnerability, where economically feasible, we will attempt to promptly fix it in order to keep your data safe. However, with governments spying online using sophisticated technology and hackers data mining sites, no website owner can guarantee your information will be completely safe from unauthorized access by others. Please take these security risks into account before giving information to us or any other website owner.

Data Retention

We will keep your data for as long as we need it to provide you with products and services, comply with applicable law, resolve any disputes between us or with third parties, and to enforce any contracts between us.

California Privacy Rights

If you are a California resident and our customer, Cal. Civ. Code § 1798.83 permits you to request certain information about our disclosure of personal information to third parties for their direct marketing purposes. To request this information, please send an email to Support[at]ascensionodyssey.com or write us at the following address:

Ascension Odyssey.

P.O. Box 600292 Jacksonville, FL 32260

Jacksonville, FL 32260

USA

If you reside in the State of California, you may have certain privacy rights under the California Consumer Privacy Act of 2018, Cal. Civ. Code § 1798.100 to § 1798.199 (“CaCPA”). However, the CaCPA does not apply to us for one or more of the following reasons: (1) we are a small or medium-sized enterprise (“SME”) that is not a “business” as such term is defined in Subsection 1798.140(c) of the CaCPA; and (2) other laws apply to us that conflict with and/or supersede the CaCPA.

Even though we do not have a legal obligation to do so, we may respond to your requests made per the CaCPA. However, these voluntary responses are not a waiver of our legal rights and obligations under the laws of FL and USA or the arbitration provisions found within our website’s Terms and Conditions of Use.

European Union Privacy Rights

If you reside in the European Union, you may have certain privacy rights under Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), to the extent the GDPR does not conflict with the laws of FL and USA. Even if we do not have a legal obligation to do so, we may respond to your requests made per the GDPR. However, voluntary responses are not a waiver of our legal rights and obligations under the laws of FL and USA or the arbitration provisions found within our website’s Terms and Conditions of Use.

Small Or Medium-Sized Enterprise Status

We are a small or medium-sized enterprise (“SME”). This means that because of the size of our business, to the extent (if any) the GDPR governs our relationship with you, some of GDPR’s obligations do not apply because we are an SME.

How To Make A Request

To make a GDPR request, please send an email to Support[at]ascensionodyssey.com or write us at the following address:

Ascension Odyssey.

P.O. Box 600292 Jacksonville, FL 32260

Jacksonville, FL 32260

USA

We will respond within thirty (30) days of receipt of your request.

Requests To Access Personal Data

If we grant your request to access personal data, we will: (1) confirm whether or not we are processing your personal data; (2) provide you with a copy of any of your personal data that we possess; and (3) provide you with information about how we process such data (e.g. purposes, categories, recipients, etc.).

Requests To Delete Data

If you request that we delete your personal data that we possess, we will do so unless: (1) the data is needed to exercise the right of freedom of expression; (2) we have a legal obligation to keep the data; (3) we must keep the data for reasons of public interest; or (4) the data has been processed so that it is anonymized.

Any personal data we processed unlawfully will be deleted. If you were a minor when we collected the personal data, we will delete the data upon request.

If we believe any third parties have acquired your personal data through us, we will take reasonable steps to inform them that you have requested erasure of such data.

Objections To Processing Of Personal Data

If your request is an objection to the processing of your personal data for directing marketing purposes, we will cease using your data for such purposes.

As a general rule, we will comply with objections to processing personal data except: (1) where it is not technically or commercially feasible to do so; or (2) we have a legal obligation that overrides your individual rights and freedoms.

Portability Requests

If we collected personal data from you because of a contract between us or based on your consent, and we processed that data by automated means (in structured machine-readable format), you can request that data be transmitted by us to another company or organization.

We will provide such data to the recipient third party in a commonly used open format electronic file (e.g. CSV, JSON, XML, etc.).

Denied Requests

If we reject your request, we will provide you with the reason(s) for doing so. You may then choose to file a complaint with the Data Protection Authority and request a judicial remedy to the extent such a request is not in conflict with the laws of laws of FL and USA or the arbitration provisions of our website’s Terms and Conditions of Use).

Processing Fees

As a general rule, there is no fee for processing your GDPR request. However, we reserve the right to refuse your request or charge a reasonable fee for processing it if the request is manifestly unfounded or excessive. For example, it would be excessive to make a repetitive second request to access your personal data one month after we provided you with the data from a prior request.

Automated Processing

We may make decisions through automated processing (e.g. algorithms) of personal data that are legally binding or significantly affect you.

Any such automated decision-making is done per your express consent or because it is necessary for reasons of substantial public interest under applicable law.

Such an automated decision may be made based on relevant law. However, if the decision is made for other reasons, we will inform you of the process’ logic and potential consequences of the decision. To the extent that the GDPR does not conflict with the laws of FL and USA or the arbitration provisions found within our website’s Terms and Conditions of Use, you may also have a right to obtain human intervention and contest the automated decision.

Force Majeure

We, our principals, employees, and agents shall not be liable for failure to perform any of our obligations under this policy during any period in which we cannot perform due to fire, earthquake, flood, or other natural disaster, epidemic, pandemic, explosion, casualty, war, terrorism, embargo, riot, civil disturbance, act of public enemy, act of God, or the intervention of any government authority, or similar cause beyond our control.

Policy Changes

The terms of this privacy policy may change from time to time. If such changes are made, we will notify you by a notice posted on our website’s home page of the changes that have been made. If you disagree with the changes that have been made, please contact us (by email, using a website contact form, or in writing by mail), and any changes made to this policy will not apply to information we have collected from you prior to making the changes.

By continuing to access our website after changes to this privacy policy go into effect, you are agreeing to be legally bound by the revised policy.

If you are concerned about the topic covered by this website privacy policy, you should read it each time before you use our website.

Questions or Concerns

Any questions or concerns about this website privacy policy should be brought to our attention by sending an email to Support[at]ascensionodyssey.com and providing us with information relating to your concern.

You may also mail your concerns to us at the following address:

Ascension Odyssey.

P.O. Box 600292 Jacksonville, FL 32260

Jacksonville, FL 32260

USA

This website privacy policy was last updated on July 20, 2020.

Copyright © 2008-2020 Law Office of Michael E. Young PLLC and generated with Website Legal Forms Generator software, and licensed for use by the owner of this Website at ascensionodyssey.com. All Rights Reserved. No portion of this document may be copied or used by anyone other than the licensee without the express written permission of the copyright owner. Use of this document does not make the website owner a client of the law firm. Contact the website owner with any questions or concerns about this site.

 

Data Processing Clauses

 

 

Note to User

Ideally, we recommend that you will have a separate data processing agreement that will set out the terms on how data will be held and used. If this is not going to be possible, the next step is to try and negotiate or revise existing agreements, terms etc. to incorporate a clause which acknowledges GDRP and that you will aim to comply with this.  On this basis the clause below is recommended.

You will also need to complete the information requested in the Processing, Personal Data and Data Subjects Schedule 1 outline (included on page four) under the suggested headings.

 

Contract Clauses

1. Definitions

• Data Protection Legislation: (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998.

2. Data Protection
   • In so far as required, both parties agree that they will comply with all applicable requirements of the Data Protection Legislation. This clause 2.1 is in addition to, and does not relieve, remove or replace, a party’s obligations under the Data Protection Legislation.
   • The parties acknowledge that for the purposes of the Data Protection Legislation, the Customer is the data controller and the Provider is the data processor (where Data Controller and Data Processor have the meanings as defined in the Data Protection Legislation). Schedule 1 sets out the scope, nature and purpose of processing by the Provider, the duration of the processing and the types of personal data (as defined in the Data Protection Legislation, Personal Data) and categories of Data Subject.
   • Without prejudice to the generality of clause 1.1, the Customer will ensure that it has all necessary appropriate consents and notices in place to enable lawful transfer of the Personal Data to the Provider for the duration and purposes of this agreement.
   • Without prejudice to the generality of clause 1.1, the Provider warrants and undertakes that it shall, in relation to any Personal Data processed in connection with the performance by the Provider of its obligations under this agreement:
     • process that Personal Data only on the written instructions of the Customer unless the Provider is required by the laws of any member of the European Union or by the laws of the European Union applicable to the Provider to process Personal Data (Applicable Laws). Where the Provider is relying on laws of a member of the European Union or European Union law as the basis for processing Personal Data, the Provider shall promptly notify the Customer of this before performing the processing required by the Applicable Laws unless those Applicable Laws prohibit the Provider from so notifying the Customer;
     • ensure that it has in place appropriate technical and organisational measures, reviewed and approved by the Customer, to protect against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data, appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures (those measures may include, where appropriate, pseudonymising and encrypting Personal Data, ensuring confidentiality, integrity, availability and resilience of its systems and services, ensuring that availability of and access to Personal Data can be restored in a timely manner after an incident, and regularly assessing and evaluating the effectiveness of the technical and organisational measures adopted by it);
     • ensure that all personnel who have access to and/or process Personal Data are obliged to keep the Personal Data confidential; and
     • not transfer any Personal Data outside of the European Economic Area unless the prior written consent of the Customer has been obtained and the following conditions are fulfilled:
       • the Customer or the Provider has provided appropriate safeguards in relation to the transfer;
       • the data subject has enforceable rights and effective legal remedies;
       • the Provider complies with its obligations under the Data Protection Legislation by providing an adequate level of protection to any Personal Data that is transferred; and
       • the Provider complies with reasonable instructions notified to it in advance by the Customer with respect to the processing of the Personal Data;
     • assist the Customer, at the Customer’s cost, in responding to any request from a Data Subject and in ensuring compliance with its obligations under the Data Protection Legislation with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators;
     • notify the Customer without undue delay on becoming aware of a Personal Data breach;
     • at the written direction of the Customer, delete or return Personal Data and copies thereof to the Customer on termination of the agreement unless required by Applicable Law to store the Personal Data; and
     • maintain complete and accurate records and information to demonstrate its compliance with this clause (and allow for audits by the Customer or the Customer’s designated auditor).

 

• The Customer does not consent to the Provider appointing any third party processor of Personal Data under this agreement. OR The Customer consents to the Provider appointing Active Member 360, Infusionsoft, Clickfunnels, Active Champaign, and other essential third party services as a third-party processor of Personal Data under this agreement. The Provider confirms that it has entered or (as the case may be) will enter with the third-party processor into a written agreement substantially on that third party’s standard terms of business OR incorporating terms which are substantially similar to those set out in this clause. As between the Customer and the Provider, the Provider shall remain fully liable for all acts or omissions of any third-party processor appointed by it pursuant to this clause.
• Either party may, at any time on not less than 30 days’ notice, revise this clause [NUMBER] by replacing it with any applicable controller to processor standard clauses or similar terms forming party of an applicable certification scheme (which shall apply when replaced by attachment to this agreement).
• Each party agrees to indemnify and keep indemnified and defend at its own expense the other party against all costs, claims, damages or expenses incurred by the other party or for which the other party may become liable due to any failure by the first party or its employees or agents to comply with any of its obligations under this clause.

 

• Processing, Personal Data and Data Subjects

 

1. Processing by the Provider
   • Scope

For business purposes.

• Nature

For business purposes.

• Purpose of processing

For business purposes.

• Duration of the processing

For as long as necessary regarding business purposes.

2. Types of personal data

Personal and biometric data.

3. Categories of data subject

Personal and biometric data.

 

Ascension Odyssey

Data Protection Policy

 

Table of Contents

Section A: Overview……………………………………………………………………………………………………………2

Section B: Data Protection Principles………………………………………………………………………………………5

Section C: Data Subject Rights………………………………………………………………………………………………7

Section D: Our Other Obligations………………………………………………………………………………………..12

Schedule 1: Our Use Of Personal Data And Our Purpose………………………………………………………..15

Schedule 2: Our Specific Data Protection Measures………………………………………………………………16

 

This Policy has been approved and authorised by:

Name:	Ascension Odyssey
Date:	7/20/2020

Section A: Overview

 

1. The reason for this policy
   • You have legal rights with regard to the way your personal data is handled.
   • In the course of our business activities we collect, store and process personal data about our customers, suppliers and other third parties, and therefore in order to comply with the law and to maintain confidence in our business, we acknowledge the importance of correct and lawful treatment of this data.
   • All people working in or with our business are obliged to comply with this policy when processing personal data.

 

2. Introduction
   • This policy and any other documents referred to in it sets out the basis on which we will process any personal data we collect from data subjects, for example, customers and business contacts, or that is provided to us by data subjects or other sources.
   • It also sets out our obligations in relation to data protection under the General Data Protection Regulation (“the Regulation”).
   • This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer and store personal data.
   • The procedures and principles set out herein must be followed at all times by us and our employees, agents, contractors, or other parties working on behalf of the Company.
   • We aim to ensure the correct, lawful, and fair handling of your personal data and to respect your legal rights.

 

3. The meaning of key Data Protection terms
   • Data is information which is stored electronically, on a computer, or in certain paper-based filing systems.
   • Data subjects for the purpose of this policy include all living individuals about whom we holds personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.
   • Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.
   • Data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with the Act. We are the data controller of all personal data used in our business for our own commercial purposes.
   • Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

 

4. Summary of the Data Protection Principles

This Policy aims to ensure compliance with the Regulation.  The Regulation sets out the following principles with which any party handling personal data must comply.  All personal data must be:

1. (Processed fairly and lawfully) processed lawfully, fairly, and in a transparent manner in relation to the data subject;
2. (Processed for limited purposes and in an appropriate way) collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. (Adequate, relevant and not excessive for the purpose) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
4. (Accurate) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
5. (Not kept longer than necessary for the purpose) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;
6. (Processing in line with data subject’s rights) personal data must be processed in line with data subjects’ rights, in particular your right to:
   • request access to any data held about them by a Data Controller (see also clause 15).
   • prevent the processing of their data for direct-marketing purposes.
   • ask to have inaccurate data amended (see also clause 9).
   • prevent processing that is likely to cause damage or distress to themselves or anyone else.
7. (Security) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
8. (Transfers outside EEA) not transferred to people or organisations situated in countries without adequate protection.

 

5. Our use of personal data and our purpose

We collect, hold, and process the personal data referred to in Schedule 1 (and the purpose for which we process that personal data is also set out in Schedule 1).

 

6. Our data protection measures

When we are working with personal data we take the measures set out in Schedule 2.

 

Section B:  Data Protection Principles

 

7. Lawful, Fair, and Transparent Data Processing

The Regulation is not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject.  The processing of personal data is lawful if one (or more) of the following applies:

1. (consent) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
2. (contract) processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
3. (legal obligation) processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
4. (protection) processing is necessary to protect the vital interests of the data subject or of another natural person;
5. (public interest) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
6. (legitimate interests) processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

 

8. Processed for Specified, Explicit and Legitimate Purposes
   • The Company collects and processes the personal data set out in Schedule 1 of this Policy. This may include personal data received directly from data subjects (for example, contact details used when a data subject communicates with us) and can include data received from third parties.
   • The Company only processes personal data for the specific purposes set out in Schedule 1 of this Policy (or for other purposes expressly permitted by the Regulation). The purposes for which we process personal data will be informed to data subjects at the time that their personal data is collected, where it is collected directly from them, or as soon as possible (not more than one calendar month) after collection where it is obtained from a third party.

 

9. Adequate, Relevant and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose(s) informed to data subjects as under Part 5, above.

 

10. Accuracy of Data and Keeping Data Up To Date

The Company shall ensure that all personal data collected and processed is kept accurate and up-to-date.  The accuracy of data shall be checked when it is collected and at regular intervals thereafter.  Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

 

11. Timely Processing

The Company shall not keep personal data for any longer than is necessary in light of the purposes for which that data was originally collected and processed.  When the data is no longer required, all reasonable steps will be taken to erase it without delay.

 

12. Secure Processing

The Company shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage.  Further details of the data protection and organisational measures which shall be taken are provided in Parts 22 and 23 of this Policy.

• An assessment of the risks posed to individual data subjects; and
• Details of the measures in place to minimise and handle risks including safeguards, data security, and other measures and mechanisms to ensure the protection of personal data, sufficient to demonstrate compliance with the Regulation.

 

Section C: Data Subject Rights

13. The Rights of Data Subjects

The Regulation sets out the following rights applicable to data subjects:

1. The right to be informed;
2. The right of access;
3. The right to rectification;
4. The right to erasure (also known as the ‘right to be forgotten’);
5. The right to restrict processing;
6. The right to data portability;
7. The right to object;
8. Rights with respect to automated decision-making and profiling.

 

14. Keeping Data Subjects Informed
    • The Company shall ensure that the following information is provided to every data subject when personal data is collected:
      1. Details of the Company including, but not limited to, the identity of Herta Woodward, its Data Protection Officer;
      2. The purpose(s) for which the personal data is being collected and will be processed (as detailed in Schedule 1 of this Policy) and the legal basis justifying that collection and processing;
      3. Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
      4. Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
      5. Where the personal data is to be transferred to one or more third parties, details of those parties;
      6. Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 26 of this Policy for further details concerning such third country data transfers);
      7. Details of the length of time the personal data will be held by the Company (or, where there is no predetermined period, details of how that length of time will be determined);
      8. Details of the data subject’s rights under the Regulation;
      9. Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
      10. Details of the data subject’s right to complain to the Information Commissioner’s Office (the ‘supervisory authority’ under the Regulation);
      11. Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it;
      12. Details of any automated decision-making that will take place using the personal data (including but not limited to profiling), including information on how decisions will be made, the significance of those decisions and any consequences.
    • The information set out above in Part 14.1 shall be provided to the data subject at the following applicable time:
      • Where the personal data is obtained from the data subject directly, at the time of collection;
      • Where the personal data is not obtained from the data subject directly (i.e. from another party):
        1. If the personal data is used to communicate with the data subject, at the time of the first communication; or
        2. If the personal data is to be disclosed to another party, before the personal data is disclosed; or
        3. In any event, not more than one month after the time at which the Company obtains the personal data.

 

15. Data Subject Access
    • A data subject may make a subject access request (“SAR”) at any time to find out more about the personal data which the Company holds about them. The Company is normally required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
    • All subject access requests received must be forwarded to the Company’s data protection officer. Support@AscensionOdyssey.com.
    • The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

 

16. Rectification of Personal Data
    • If a data subject informs the Company that personal data held by the Company is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified, and the data subject informed of that rectification, within one month of receipt the data subject’s notice (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
    • In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification of that personal data.

 

17. Erasure of Personal Data
    • Data subjects may request that the Company erases the personal data it holds about them in the following circumstances:
      1. It is no longer necessary for the Company to hold that personal data with respect to the purpose for which it was originally collected or processed;
      2. The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
      3. The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 20 of this Policy for further details concerning data subjects’ rights to object);
      4. The personal data has been processed unlawfully;
      5. The personal data needs to be erased in order for the Company to comply with a particular legal obligation.
    • Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
    • In the event that any personal data that is to be erased in response to a data subject request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

 

18. Restriction of Personal Data Processing
    • Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.
    • In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

 

19. Data Portability
    • The Company processes personal data using automated means.
    • Where data subjects have given their consent to the Company to process their personal data in such a manner or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the legal right under the Regulation to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other Data Controllers, e.g. other organisations).
    • To facilitate the right of data portability, the Company shall make available all applicable personal data to data.
    • Where technically feasible, if requested by a data subject, personal data shall be sent directly to another Data Controller.
    • All requests for copies of personal data shall be complied with within one month of the data subject’s request (this can be extended by up to two months in the case of complex requests in the case of complex or numerous requests, and in such cases the data subject shall be informed of the need for the extension).

 

20. Objections to Personal Data Processing
    • Data subjects have the right to object to the Company processing their personal data based on legitimate interests (including profiling), direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.
    • Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing forthwith, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.
    • Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing forthwith.
    • Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Regulation, ‘demonstrate grounds relating to his or her particular situation’. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

 

21. Automated Decision-Making
    • In the event that the Company uses personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on data subjects, data subjects have the right to challenge to such decisions under the Regulation, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.
    • The right described in Part 21.1 does not apply in the following circumstances:
      1. The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject;
      2. The decision is authorised by law; or
      3. The data subject has given their explicit consent.

 

22. Profiling

Where the Company uses personal data for profiling purposes, the following shall apply:

1. Clear information explaining the profiling will be provided, including its significance and the likely consequences.
2. Appropriate mathematical or statistical procedures will be used;
3. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
4. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 22 and 23 of this Policy for more details on data security).

 

Section D: Our Other Obligations

23. Accountability
    • The Company’s data protection officer is Herta Woodward, Support@AscensionOdyssey.com.
    • The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
      1. The name and details of the Company, its data protection officer, and any applicable third party Data Controllers;
      2. The purposes for which the Company processes personal data;
      3. Details of the categories of personal data collected, held, and processed by the Company; and the categories of data subject to which that personal data relates;
      4. Details (and categories) of any third parties that will receive personal data from the Company;
      5. Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
      6. Details of how long personal data will be retained by the Company; and
      7. Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

24. Privacy Impact Assessments

The Company shall carry out Privacy Impact Assessments when and as required under the Regulation.  Privacy Impact Assessments shall be overseen by the Company’s data protection officer and shall address the following areas of importance:

• The purpose(s) for which personal data is being processed and the processing operations to be carried out on that data;
• Details of the legitimate interests being pursued by the Company;
• An assessment of the necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;

25. Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

1. All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
2. Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
3. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
4. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
5. Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
6. The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
7. All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
8. All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation;
9. Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

 

26. Transferring Personal Data to a Country Outside the EEA
    • The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
    • The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
      1. The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
      2. The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Regulation); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
      3. The transfer is made with the informed consent of the relevant data subject(s);
      4. The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
      5. The transfer is necessary for important public interest reasons;
      6. The transfer is necessary for the conduct of legal claims;
      7. The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
      8. The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

 

27. Data Breach Notification
    • All personal data breaches must be reported immediately to the Company’s data protection officer.
    • If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the data protection officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
    • In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 27.2) to the rights and freedoms of data subjects, the data protection officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
    • Data breach notifications shall include the following information:
      1. The categories and approximate number of data subjects concerned;
      2. The categories and approximate number of personal data records concerned;
      3. The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
      4. The likely consequences of the breach;
      5. Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

 

28. Implementation of Policy

This Policy shall be deemed effective as of 7/20/2020.  No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

 

Schedule 1: Our Use Of Personal Data And Our Purpose

The following personal data may be collected, held, and processed by the Company:

1. Personal and Biometric data may be collected and processed for business purposes with the consent given for use at the time the data was acquired.

 

Schedule 2:  Our Specific Data Protection Measures

These are the measures we take when working with personal data:

1. All emails containing personal data must be encrypted secure types of encryption;
2. Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies should be shredded, and electronic copies should be deleted securely using secure deletion methods.
3. Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
4. Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
5. Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted.  All temporary files associated therewith should also be deleted;
6. Where Personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
7. Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using a secure delivery service;
8. No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from Support@AscensionOdyssey.com.
9. All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar;
10. No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of AscensionOdyssey.com. Which can be contacted at Support@AscensionOdyssey.com
11. Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;
12. If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;
13. No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of [Insert Name(s) and/or position(s) and contact details and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.
14. No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);
15. All personal data stored electronically should be backed up annually with backups stored onsite AND/OR offsite. All backups should be encrypted using secure methods of encryption such as passwords.
16. All electronic copies of personal data should be stored securely using passwords and other secure forms of data encryption;
17. All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must  contain some of the following combination characteristics of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords;
18. Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method.  IT staff do not have access to passwords;
19. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of Ascension Odyssey Support@AscensionOdyssey.com to ensure that no data subjects have added their details to any marketing preference databases including, but not limited to, the Telephone Preference Service, the Mail Preference Service, the Email Preference Service, and the Fax Preference Service. Such details should be checked at least annually.

 

 

 

Data Retention Policy

 

Introduction

This data retention policy sets out the obligations of Ascension Odyssey (“us/we/our”) and the basis upon which we shall retain, review and destroy data held by us, or within our custody or control.

This policy applies to our entire organisation including our officers, employees, agents and sub-contractors and sets out what the retention periods are and when any such data may be deleted.

Objectives

It is necessary to retain and process certain information to enable our business to operate. We may store data in the following places:

• our own servers;
• any third party servers;
• potential email accounts;
• desktops;
• employee-owned devices (BYOD);
• potential backup storage; and/or
• our paper files.

This policy applies equally to paper, electronic media and any other method used to store personal data. The period of retention only commences when the record is closed.

We are bound by various obligations under the law in relation to this and therefore, to comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully in respect of their personal data under the General Data Protection Regulation (“the Regulation”).

The Regulation defines “personal data” as any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets out the procedures that are to be followed when dealing with personal data and how we aim to comply with the Regulation in so far as it is possible. In summary, the Regulation states that all personal data shall be:

1. processed lawfully, fairly, and in a transparent manner in relation to the data subject;
2. collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

The Fourth and Fifth Data Protection Principles require that any data should not be kept longer than necessary for the purpose for which it is processed and when it is no longer required, it shall be deleted and that the data should be adequate, relevant and limited for the purpose in which it is processed.

With this in mind, this policy should be read in conjunction with our other policies which are relevant such as our data protection policy and IT security policy.

 

Security and Storage

All data and records are stored securely to avoid misuse or loss. We will process all personal data we hold in accordance with our IT Security Policy [OR take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data].

We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if there is agreement by them to comply with those procedures and policies, or if there are adequate measures in place.

Examples of our storage facilities are as follows:

Active Member 360, Infusionsoft, Clickfunnels, Active Champaign, and other essential third party services.

We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:

(a)                                            Confidentiality means that only people who are authorised to use the data can access it.

(b)           Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.

(c)            Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on the [COMPANY’S] central computer system instead of individual PCs.

 

Retention Policy

Data retention is defined as the retention of data for a specific period of time and for back up purposes.

We shall not keep any personal data longer than necessary, but acknowledge that this will be dependent on the different types of documents and data that we have responsibility for. As such, our general data retention shall only be as long as necessary used for business purposes.  Our specific data retention periods are set out below:

 

Type of data	Type of data subject	Type of processing	Purpose of processing	Type of recipient to whom personal data is transferred	Retention period	Data accuracy and minimisation review date
Customers	Personal and biometric data.	For business purposes.	For business purposes.	Used for business purposes.	As long as necessary.	Annually
Business contacts	Personal and biometric data.	For business purposes.	For business purposes.	Used for business purposes.	As long as necessary.	Annually

 

From time to time, it may be necessary to retain or access historic personal data under certain circumstances such as if we have contractually agreed to do so or if we have become involved in unforeseen events like litigation or business disaster recoveries.

 

Destruction and Disposal

Upon expiry of our retention periods, we shall delete confidential or sensitive records categorised as requiring high protection and very high protection, and we shall either delete or anonymise less important documents.

Our Records Management Officer is responsible for the continuing process of identifying the records that have met their required retention period and supervising their destruction. The destruction of confidential, financial, and personnel-related records shall be securely destroyed electronically or by shredding if possible. Non-confidential records may be destroyed by recycling.

Ascension Odyssey

IT Security Policy

7/21/2020

 

1. Introduction

This document sets out the measures to be taken by all employees of Ascension Odyssey (the “Company”) and by the Company as a whole in order to protect the Company’s computer systems, devices, infrastructure, computing environment and any and all other relevant equipment (collectively, “IT Systems”) from damage and threats whether internal, external, deliberate or accidental.

 

2. Key Principles
   • All IT Systems are to be protected against unauthorised access.
   • All IT Systems are to be used only in compliance with relevant Company Policies.
   • All data stored on IT Systems are to be managed securely in compliance with all relevant parts of the GDPR and all other laws governing data protection whether now or in the future in force.
   • All employees of the Company and any and all third parties authorised to use the IT Systems including, but not limited to, contractors and sub-contractors (collectively, “Users”), must ensure that they are familiar with this Policy and must adhere to and comply with it at all times.
   • All line managers must ensure that all Users under their control and direction must adhere to and comply with this Policy at all times as required under paragraph 2.4.
   • All IT Systems are to be installed, maintained, serviced, repaired and upgraded by IT Department or by such third party/parties as the IT Department may from time to time authorise.
   • The responsibility for the security and integrity of all IT Systems and the data stored thereon (including, but not limited to, the security, integrity and confidentiality of that data) lies with the IT Department unless expressly stated otherwise.
   • All breaches of security pertaining to the IT Systems or any data stored thereon shall be reported and subsequently investigated by the IT Department.
   • All Users must report any and all security concerns relating to the IT Systems or to the data stored thereon immediately to the IT Department.

 

3. IT Department Responsibilities
   • The IT Manager, shall be responsible for the following:
     1. ensuring that all IT Systems are assessed and deemed suitable for compliance with the Company’s security requirements;
     2. ensuring that IT security standards within the Company are effectively implemented and regularly reviewed, by way of periodic audits and risk assessments, with regular reports being made to the Company’s internal senior management on the condition of the Company’s information security and compliance with this Policy;
     3. ensuring organisational management and dedicated staff responsible for the development, implementation and maintenance of this Policy;
     4. carrying out vulnerability assessments and patch management by using threat protection technologies and scheduled monitoring procedures designed to identify, assess, mitigate and protect against identified security threats, viruses and other malicious code; and
     5. ensuring that all Users are kept aware of the requirements of this Policy and of all related legislation, regulations and other relevant rules whether now or in the future in force including, but not limited to, the GDPR and the Computer Misuse Act 1990.
   • The IT Department shall be responsible for the following:
     1. assisting all Users in understanding and complying with this Policy;
     2. providing all Users with appropriate support and training in IT security matters and use of IT Systems;
     3. ensuring that all Users are granted levels of access to IT Systems that are appropriate for each User, taking into account their job role, responsibilities and any special security requirements;
     4. receiving and handling all reports relating to IT security matters and taking appropriate action in response;
     5. taking proactive action, where possible, to establish and implement IT security procedures and raise User awareness;
     6. assisting the IT Manager in monitoring all IT security within the Company and taking all necessary action to implement this Policy and any changes made to this Policy in the future;
     7. ensuring that regular backups are taken of all data stored within the IT Systems at intervals no less than every year and that such backups are stored at a suitable location off the Company premises; and
     8. [ensure compliance with all IT security standards set out in ISO 27001, to the extent such standards are not covered by the obligations set out in clause 3.2 a) – g).]

 

4. Users’ Responsibilities
   • All Users must comply with all relevant parts of this Policy at all times when using the IT Systems.
   • All Users must use the IT Systems only within the bounds of English law and must not use the IT Systems for any purpose or activity which is likely to contravene any English law whether now or in the future in force.
   • Users must immediately inform the IT Department of any and all security concerns relating to the IT Systems.
   • Users must immediately inform the IT Department of any other technical problems (including, but not limited to, hardware failures and software errors) which may occur on the IT Systems.
   • Any and all deliberate or negligent breaches of this Policy by Users will be handled as appropriate under the Company’s disciplinary procedures.

 

5. Software Security Measures
   • All software in use on the IT Systems (including, but not limited to, operating systems and individual software applications) will be kept up-to-date and any and all relevant software updates, patches, fixes and other intermediate releases will be applied at the sole discretion of the IT Department. This provision does not extend to upgrading software to new ‘major releases’ (e.g. from version 1.0 to version 2.0), only to updates within a particular major release (e.g. from version 1.0 to version 1.0.1 etc.).  Unless a software update is available free of charge it will be classed as a major release and thus falls within the remit of new software procurement and outside the scope of this provision.
   • Where any security flaw is identified in any software that flaw will be either fixed immediately or the software may be withdrawn from the IT Systems until such time as the security flaw can be effectively remedied.
   • No Users may install any software of their own, whether that software is supplied on physical media (e.g. DVD-Rom) or whether it is downloaded, without the approval of the IT Manager. Any software belonging to Users must be approved by the IT Manager and may only be installed where that installation poses no security risk to the IT Systems and where the installation would not breach any licence agreements to which that software may be subject.
   • All software will be installed onto the IT Systems by the IT Department unless an individual User is given written permission to do so by the IT Manager. Such written permission must clearly state which software may be installed and onto which computer(s) or device(s) it may be installed.

 

6. Anti-Virus Security Measures
   • Most IT Systems (including all computers and servers) will be protected with suitable anti-virus, firewall and internet security software. All such anti-virus, firewall and internet security software will be kept up-to-date with the latest software updates and definitions.
   • All IT Systems protected by anti-virus software will be subject to a full system scan at least annually.
   • All storage media (e.g. USB memory sticks or disks of any kind) used by Users for transferring files must be virus-scanned before any files may be transferred. Such virus scans shall be performed automatically upon connection / insertion of media OR by the User OR by the IT Staff / Manager.
   • Users shall not be permitted to transfer files using cloud storage systems. All files downloaded from any cloud storage system must be scanned for viruses during the download process.
   • Any files being sent to third parties outside the Company, whether by email, on physical media or by other means (e.g. FTP or shared cloud storage) must be scanned for viruses before being sent or as part of the sending process, as appropriate. All email attachments are scanned automatically upon sending.
   • Where any virus is detected by a User this must be reported immediately to the IT Department (this rule shall apply even where the anti-virus software automatically fixes the problem). The IT Department shall promptly take any and all necessary action to remedy the problem.  In limited circumstances this may involve the temporary removal of the affected computer or device.  Wherever possible a suitable replacement computer or device will be provided within 6  months to limit disruption to the User.
   • Where any User deliberately introduces any malicious software or virus to the IT Systems this will constitute a criminal offence under the Computer Misuse Act 1990 and will be handled as appropriate under the Company’s disciplinary procedures.

 

7. Hardware Security Measures
   • Wherever practical, IT Systems will be located in rooms which may be securely locked when not in use or, in appropriate cases, at all times whether in use or not (with authorised Users being granted access by means of a key, smart card, door code or similar). Where access to such locations is restricted, Users must not allow any unauthorised individual access to such locations for any reason.
   • All IT Systems not intended for normal use by Users (including, but not limited to, servers, networking equipment and network infrastructure) and any other areas where personal data may be stored (eg. data centre or server room facilities) shall be designed to (i) protect information and physical assets from unauthorised physical access, (ii) manage, monitor and log movement of persons into and out of the relevant facilities, and (iii) guard against environmental hazards such as heat, fire and water damage.
   • No Users shall have access to any IT Systems not intended for normal use by Users (including such devices mentioned above) without the express permission of the IT Manager. Under normal circumstances whenever a problem with such IT Systems is identified by a User, that problem must be reported to the IT Department.  Under no circumstances should a User attempt to rectify any such problems without the express permission (and, in most cases, instruction and/or supervision) of the IT Manager.
   • All non-mobile devices (including, but not limited to, desktop computers, workstations and monitors) shall, wherever possible and practical, be physically secured in place with a suitable locking mechanism. Where the design of the hardware allows, computer cases shall be locked to prevent tampering with or theft of internal components.
   • All mobile devices (including, but not limited to, laptops, netbooks, tablets, PDAs and mobile telephones) provided by the Company should always be transported securely and handled with care. In circumstances where such mobile devices are to be left unattended they should be placed inside a lockable case or other suitable container.  Users should make all reasonable efforts to avoid such mobile devices from being left unattended at any location other than their private homes or Company premises.  If any such mobile device is to be left in a vehicle it must be stored out of sight.
   • The IT Department shall maintain a complete asset register of all IT Systems. All IT Systems shall be labelled and the corresponding data shall be kept on the asset register.

 

8. Access Security
   • All IT Systems (and in particular mobile devices including, but not limited to, laptops, netbooks, tablets, PDAs and mobile telephones) shall be protected with a secure password or such other form of secure log-in system as the IT Department may deem appropriate. Such alternative forms of secure log-in may include fingerprint identification and facial recognition.
   • Logical access controls designed to manage electronic access to data and IT System functionality based on authority levels and job functions, (e.g. granting access on a need-to-know and least privilege basis, use of unique IDs and passwords for all Users, periodic review and revoking/changing access promptly when employment terminates or changes in job functions occur).
   • All passwords must, where the software, computer or device allows:
     • be at secure;
     • contain different combination of symbols;
     • may be changed every 2 years;
     • be different from the previous password;
     • not be obvious or easily guessed (e.g. birthdays or other memorable dates, memorable names, events or places etc.);
     • be created by individual Users; and
     • newly issued passwords must be changed after first use
   • Passwords should be kept secret by each User. Under no circumstances should a User share their password with anyone including the IT Manager and the IT Staff.  No User will be legitimately asked for their password by anyone at any time and any such request should be refused.  If a User has reason to believe that another individual has obtained their password they should change their password immediately and report the suspected breach of security to the IT Department.
   • If a User forgets their password, this should be reported to the IT Department. The IT Department will take the necessary steps to restore the User’s access to the IT Systems which may include the issuing of a temporary password which may be fully or partially known to the member of the IT Staff responsible for resolving the issue.  A new password must be set up by the User immediately upon the restoration of access to the IT Systems.
   • All IT Systems with displays and user input devices (e.g. mouse, keyboard, touchscreen etc.) shall be protected, where possible, with a password protected screensaver that will activate after one year of inactivity. This time period cannot be changed by Users and Users may not disable the screensaver.  Activation of the screensaver will not interrupt or disrupt any other activities taking place on the computer (e.g. data processing).
   • The IT Department shall conduct regular system audits or event logging and related monitoring procedures to proactively record User access and activity on the IT Systems for routine review.
   • Users may not use any software which may allow outside parties to access the IT Systems without the express consent of the IT Manager. Any such software must be reasonably required by the User for the performance of their job role and must be fully inspected and cleared by the IT Manager.
   • Users may connect their own devices (including, but not limited to, mobile telephones, tablets and laptops) to the Company network subject to the approval of the IT Department. Any and all instructions and requirements provided by the IT Department governing the use of Users’ own devices when connected to the Company network must be followed at all times.  Users’ use of their own devices shall be subject to, and governed by, all relevant Company Policies (including, but not limited to, this Policy) while those devices are connected to the Company network or to any other part of the IT Systems.  The IT Department shall reserve the right to request the immediate disconnection of any such devices without notice.

 

9. Data Protection
   • All personal data (as defined in the General Data Protection Regulation (“GDPR”)) collected, held and processed by the Company will be collected, held and processed strictly in accordance with the GDPR and the Company’s Data Protection Policy.
   • The IT Department shall ensure there are data security controls which include at a minimum, but may not be limited to, logical segregation of data, restricted (e.g. role-based) access and monitoring, and utilisation of commercially available and industry standard encryption technologies for personal data that is:
     1. transmitted over public networks (i.e. the Internet) or when transmitted wirelessly; or
     2. at rest or stored on portable or removable media (i.e. laptop computers, CD/DVD, USB drives, back-up tapes).

 

• All emails containing personal data must be encrypted secure types of encryption.
• Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted.  All temporary files associated therewith should also be deleted.
• Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data.
• If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it.
• No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).
• The IT Department shall ensure operational procedures and controls to provide to provide for the secure disposal of any part of the IT Systems or any media to render all information or data contained therein as undecipherable or unrecoverable prior to final disposal or release from the Company’s possession.
• Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies should be shredded, and electronic copies should be deleted securely using secure encryption methods.
• The IT Department shall ensure that it has in place appropriate technical and, to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures (those measures may include, where appropriate, pseudonymising and encrypting personal data, ensuring confidentiality, integrity, availability and resilience of its systems and services, ensuring that availability of and access to personal data can be restored in a timely manner after an incident, and regularly assessing and evaluating the effectiveness of the technical and organisational measures adopted by it).
• All personal data stored electronically should be backed up annually with backups stored onsite AND/OR offsite. All backups should be encrypted using secure encryption methods.
• All electronic copies of personal data should be stored securely using passwords and secure data encryption.
• Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of Ascension Odyssey Support@AscensionOdyssey.com to ensure that no data subjects have added their details to any marketing preference databases including, but not limited to, the Telephone Preference Service, the Mail Preference Service, the Email Preference Service, and the Fax Preference Service. Such details should be checked at least annually.
• Only Users that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company.
• All Users handling personal data for and on behalf of the Company shall be subject to, and must comply with, the provisions of the Company’s Data Protection Policy.

 

10. Internet and Email Use
    • All Users shall be subject to, and must comply with, the provisions of the Company’s Communications, Email and Internet Policy when using the IT Systems.
    • Where provisions in this Policy require any additional steps to be taken to ensure IT security when using the internet or email over and above the requirements imposed by the Communications, Email and Internet Policy, Users must take such steps as required.
11. Reporting IT Security Breaches
    • All concerns, questions, suspected breaches or known breaches shall be referred immediately to the IT Department OR the IT Manager.
    • Upon receiving a question or notification of a breach, the IT Department shall, within one year assess the issue including, but not limited to, the level of risk associated therewith, and shall take any and all such steps as the IT Department deems necessary to respond to the issue.
    • Under no circumstances should a User attempt to resolve an IT security breach on their own without first consulting the IT Department. Users may only attempt to resolve IT security breaches under the instruction of, and with the express permission of, the IT Department.
    • All IT security breaches, whether remedied by the IT Department or by a User under the IT Department’s direction, shall be fully documented.

 

12. Business Continuity

The Company shall have in place adequate business resiliency/continuity and disaster recovery procedures designed to maintain any information and the supply of any service and/or recovery from foreseeable emergency situations or disasters.

13. Implementation of Policy

This Policy shall be deemed effective as of 7/21/2020.  No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

 

This Policy has been approved and authorised by:

Ascension Odyssey.
Date: 7/21/2020

 

 

Ascension Odyssey

Privacy Policy and Cookie Policy

7/20/2020

 

 

Background: Ascension Odyssey understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.

 

This Policy applies to Our use of any and all data collected by us in relation to your use of Our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

 

1.                  Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

 

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;]
“Our Site”	means this website, AscensionOdyssey.com
“USA and EU Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]
“We/Us/Our”	means Ascension Odyssey , a limited whose main trading P.O. Box 600292 Jacksonville FL, 32260

 

2.                  Information About Us

2.1               Our Site, AscensionOdyssey.com, is owned and operated by Ascension Odyssey and whose main trading address is P.O. Box 600292 Jacksonville Fl, 32260

2.2               Our data protection officer is Herta Woodward who can be contacted at Support@AscensionOdyssey.com

3.                  Scope – What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

 

4.                  What Data Do We Collect?

Some data will be collected automatically by Our Site for further details, please see section 12 on Our use of Cookies, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data:

4.1               Name

4.2               contact information such as email addresses and telephone numbers

4.3               demographic information such as post code, preferences and interests

4.4               financial information such as credit / debit card numbers

4.5               IP address (automatically collected)

4.6               web browser type and version (automatically collected)

4.7               operating system (automatically collected)

4.8               a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)

 

5.                  How Do We Use Your Data?

5.1               All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.

5.2               We use your data to provide the best possible products and services to you. This includes:

5.2.1    Providing and managing your Account

5.2.2    Providing and managing your access to Our Site

5.2.3    Personalising and tailoring your experience on Our Site

5.2.4    Supplying Our products and services to you

5.2.5    Personalising and tailoring Our products and services for you

5.2.6    Responding to communications from you

5.2.7    [Supplying you with email Insert Type of Email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the unsubscribe link at the button of every email we send out.

5.2.8    Market research

5.2.9    Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience

5.3               n some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the [products and] services We can provide you without your consent for Us to be able to use such data.

5.4               With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by  email  AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.

5.5               Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.

5.6               Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.  We will only process your personal data if at least one of the following basis applies:

a)        you have given consent to the processing of your personal data for one or more specific purposes;

b)        processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

c)         processing is necessary for compliance with a legal obligation to which we are  subject;

d)        processing is necessary to protect the vital interests of you or of another natural person;

e)        processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

f)             processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

6.                  How and Where Do We Store Your Data?

6.1               We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.  In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:

6.2               Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).

OR

6.2               Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements. [If We intend at any time to transfer any of your data outside the EEA, We will always obtain your consent beforehand and we have put in place the following safeguards to protect your data:

Encrypt and password protect data.

6.3               Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.

6.4               Steps We take to secure and protect your data include:

6.4.1    Encrypt and password protected data.

6.5               Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

7.                  Do We Share Your Data?

7.1               We may share your data with other companies in Our group. This includes our subsidiaries AND/OR our holding company and its subsidiaries.

7.2               We may contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:

All collected may be shared with Active Member 360, Infusionsoft, Clickfunnels, and Active Champaign,

7.3               We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

7.4               In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

8.                  What Happens If Our Business Changes Hands?

8.1               We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.

8.2               In the event that any of your data is to be transferred in such a manner, you will [not] be contacted in advance and informed of the changes.  When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.

9.                  How Can You Control Your Data?

9.1               When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details AND/OR by managing your Account.

9.2               You may also wish to sign up to one or more of the preference services operating in the USAThe Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

10.              Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it

10.1           You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

10.2           You may restrict your internet browser’s use of Cookies. For more information, see section 12.

10.3           You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems.  However, you acknowledge this may limit Our ability to provide the best possible products and services to you.

11.              How Can You Access Your Data?

You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at Support@AscensionOdyssey.com, or using the contact details below in section 14. Alternatively, please refer to Our Data Protection Policy

12.              What Cookies Do We Use and What For?

12.1           Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. For more details, please refer to section 5, above, and to section 12.6 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

12.2           By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for advertising services and for many other business function. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Site.

12.3           All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.

12.4           Before any Cookies are placed on your computer or device , subject to section 12.5 AND/OR section 12.8, you will be shown pop-up message bar etc. requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookies.

12.5           Certain features of Our Site depend on Cookies to function. USA and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.]

12.6           Our Site uses analytics services provided by Active Member 360, Infusionsoft, Clickfunnels, Active Champaign, and other third party essential services. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

12.7           The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.

12.8           The analytics service(s) used by Our Site use(s) the following Cookies: Active Member 360, Infusionsoft, Clickfunnels, Active Champaign, and other third party essential services.

12.9           You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

12.10       You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

12.11       It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.]

 

OR

 

12.              Cookies

Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our [products and] services.  By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Site for [Insert description of use of third party cookies, e.g. advertising services].  In addition, Our Site uses analytics services provided by [Insert name of analytics service provider(s)], which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. For more details, please refer to Our Cookie Policy

 

13.              Summary of Your Rights under GDPR

Under the GDPR, you have:

13.1      the right to request access to, deletion of or correction of, your personal data held by Us;

13.2      the right to complain to a supervisory authority;

13.3      be informed of what data processing is taking place;

13.4      the right to restrict processing;

13.5      the right to data portability;

13.6      object to processing of your personal data;

13.7      rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section 15 below.

14.              Automated Decision-Making and Profiling

14.1   In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

14.2 The right described in section 14.1 does not apply in the following circumstances:

a)           The decision is necessary for the entry into, or performance of, a contract between the You and Us;

b)           The decision is authorised by law; or

c)            You have given you explicit consent.

14.3      Where We use your personal data for profiling purposes, the following shall apply:

a)           Clear information explaining the profiling will be provided, including its significance and the likely consequences;

b)           Appropriate mathematical or statistical procedures will be used;

c)            Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and

d)           All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

14.4      We currently make some automated decisions for business and marketing purposes

14.5 We currently profile your personal data for the following purposes:

Business and marketing purposes

15.              Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at Support@AscensionOdyssey.com, or by submitting a support ticket to us here: https://support.ascensionodyssey.com/ Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

16.              Changes to Our Privacy Policy

We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

 

Terms and Conditions

In using this website you are deemed to have read and agreed to the following terms and conditions:

The following terminology applies to these Terms and Conditions, Privacy Statement and any disclaimer Notice and any or all Agreements: “Client”, “You” and “Your” refers to you, the person accessing this website and accepting the Company’s terms and conditions. “The Company”, “Ourselves”, “We” and “Us”, refers to our Company. “Party”, “Parties”, or “Us”, refers to both the Client and ourselves, or either the Client or ourselves. All terms refer to the offer, acceptance and consideration of payment necessary to undertake the process of our assistance to the Client in the most appropriate manner, whether by formal meetings of a fixed duration, or any other means, for the express purpose of meeting the Client’s needs in respect of provision of the Company’s stated services/products, in accordance with and subject to, prevailing English Law. Any use of the above terminology or other words in the singular, plural, capitalisation and/or he/she or they, are taken as interchangeable and therefore as referring to same.

Privacy Statement
We are committed to protecting your privacy. Authorised employees within the company on a need to know basis only use any information collected from individual Clients. We constantly review our systems and data to ensure the best possible service to our Clients. There are specific offences for unauthorised actions against computer systems and data. We will investigate any such actions with a view to prosecuting and/or taking civil proceedings to recover damages against those responsible

Confidentiality

Any information concerning the Client and their respective Client Records may be passed to third parties. However, Client records are regarded as confidential and therefore will not be divulged to any third party, other than our employees and if legally required to do so to the appropriate authorities. Clients have the right to request sight of, and copies of any and all Client Records we keep, on the proviso that we are given reasonable notice of such a request. Clients are requested to retain copies of any literature issued in relation to the provision of our services. Where appropriate, we shall issue Client’s with appropriate written information, handouts or copies of records as part of an agreed contract, for the benefit of both parties.

We will not sell, share, or rent your personal information to any third party or use your e-mail address for unsolicited mail. Any emails sent by this Company will only be in connection with the provision of agreed services and products.

 

Disclaimer

Exclusions and Limitations
The information on this web site is provided on an “as is” basis. To the fullest extent permitted by law, this Company:

▪         excludes all representations and warranties relating to this website and its contents or which is or may be provided by any affiliates or any other third party, including in relation to any inaccuracies or omissions in this website and/or the Company’s literature; and

▪         excludes all liability for damages arising out of or in connection with your use of this website. This includes, without limitation, direct loss, loss of business or profits (whether or not the loss of such profits was foreseeable, arose in the normal course of things or you have advised this Company of the possibility of such potential loss), damage caused to your computer, computer software, systems and programs and the data thereon or any other direct or indirect, consequential and incidental damages.

This Company does not however exclude liability for death or personal injury caused by its negligence. The above exclusions and limitations apply only to the extent permitted by law. None of your statutory rights as a consumer are affected.

Availability
Unless otherwise stated, the services featured on this website are only available within the United Kingdom, or in relation to postings from the United Kingdom. All advertising is intended solely for the United Kingdom market. You are solely responsible for evaluating the fitness for a particular purpose of any downloads, programs and text available through this site. Redistribution or republication of any part of this site or its content is prohibited, including such by framing or other similar or any other means, without the express written consent of the Company. The Company does not warrant that the service from this site will be uninterrupted, timely or error free, although it is provided to the best ability. By using this service you thereby indemnify this Company, its employees, agents and affiliates against any loss or damage, in whatever manner, howsoever caused.

Log Files
We use IP addresses to analyse trends, administer the site, track user’s movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. Additionally, for systems administration, detecting usage patterns and troubleshooting purposes, our web servers automatically log standard access information including browser type, access times/open mail, URL requested, and referral URL. This information is not shared with third parties and is used only within this Company on a need-to-know basis. Any individually identifiable information related to this data will never be used in any way different to that stated above without your explicit permission.

Cookies
Like most interactive web sites this Company’s website uses cookies to enable us to retrieve user details for each visit. Cookies are used in some areas of our site to enable the functionality of this area and ease of use for those people visiting. Some of our affiliate partners may also use cookies. [If you do not use cookies, delete this clause]

Links to this website
You may not create a link to any page of this website without our prior written consent. If you do create a link to a page of this website you do so at your own risk and the exclusions and limitations set out above will apply to your use of this website by linking to it.

Links from this website
We do not monitor or review the content of other party’s websites which are linked to from this website. Opinions expressed or material appearing on such websites are not necessarily shared or endorsed by us and should not be regarded as the publisher of such opinions or material. Please be aware that we are not responsible for the privacy practices, or content, of these sites. We encourage our users to be aware when they leave our site & to read the privacy statements of these sites. You should evaluate the security and trustworthiness of any other site connected to this site or accessed through this site yourself, before disclosing any personal information to them. This Company will not accept any responsibility for any loss or damage in whatever manner, howsoever caused, resulting from your disclosure to third parties of personal information.

Copyright and Trademark
Copyright and other relevant intellectual property rights exists on all text relating to the Company’s services and the full content of this website.

This Company’s logo is a registered trademark of this Company in the United Kingdom and other countries. The brand names and specific services of this Company featured on this web site are trade marked

 

 

Force Majeure

Neither party shall be liable to the other for any failure to perform any obligation under any Agreement which is due to an event beyond the control of such party including but not limited to any Act of God, terrorism, war, Political insurgence, insurrection, riot, civil unrest, act of civil or military authority, uprising, earthquake, flood or any other natural or man made eventuality outside of our control, which causes the termination of an agreement or contract entered into, nor which could have been reasonably foreseen. Any Party affected by such event shall forthwith inform the other Party of the same and shall use all reasonable endeavours to comply with the terms and conditions of any Agreement contained herein.

Waiver

Failure of either Party to insist upon strict performance of any provision of this or any Agreement or the failure of either Party to exercise any right or remedy to which it, he or they are entitled hereunder shall not constitute a waiver thereof and shall not cause a diminution of the obligations under this or any Agreement. No waiver of any of the provisions of this or any Agreement shall be effective unless it is expressly stated to be such and signed by both Parties.

General

By accessing this website [and using our services/buying our products] you consent to these terms and conditions and to the exclusive jurisdiction of the English courts in all disputes arising out of such access. If any of these terms are deemed invalid or unenforceable for any reason (including, but not limited to the exclusions and limitations set out above), then the invalid or unenforceable provision will be severed from these terms and the remaining terms will continue to apply. Failure of the Company to enforce any of the provisions set out in these Terms and Conditions and any Agreement, or failure to exercise any option to terminate, shall not be construed as waiver of such provisions and shall not affect the validity of these Terms and Conditions or of any Agreement or any part thereof, or the right thereafter to enforce each and every provision. These Terms and Conditions shall not be amended, modified, varied or supplemented except in writing and signed by duly authorised representatives of the Company.

Notification of Changes

The Company reserves the right to change these conditions from time to time as it sees fit and your continued use of the site will signify your acceptance of any adjustment to these terms. If there are any changes to our privacy policy, we will announce that these changes have been made on our home page and on other key pages on our site. If there are any changes in how we use our site Clients’ Personally Identifiable Information, notification by e-mail or postal mail will be made to those affected by this change. Any changes to our privacy policy will be posted on our web site 30 days prior to these changes taking place. You are therefore advised to re-read this statement on a regular basis

 

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