Privacy Policy
Optimal Track Ltd Privacy Policy

Effective 25th May 18, in accordance with the requirements of the General Data Protection Regulation (GDPR). Last updated 19th November 2018.
In this document, “we”, “our”, or “us” refer to Optimal Track Ltd, a company registered in England and Wales (registered number 5285196) whose registered office is at 47 High Street, Barnet, Herts, United Kingdom, EN5 5UW.

1. Introduction

This is the privacy policy of Optimal Track Ltd. It sets out how we use and protect any information that you give us when you use our services. It applies to data shared online, stored in our computer system or in hard copy. This privacy policy applies to the michaelnicholas.com website and all products and services offered by Optimal Track Ltd.
Your personal information is important to us, and we are committed to protecting and respecting your privacy and the confidentiality of your personal information, and to acting in compliance with the General Data Protection Regulation. Where we ask you to provide information by which you can be identified when using our websites, or any of our services, you can be assured that it will only be used in accordance with this Privacy Policy. We will always explain clearly what data we are collecting about you and why. We will only collect data we need to give you a better experience: to improve and deliver our services to you, to meet our legitimate interests and to meet our responsibilities to you. And we follow strict security procedures for the storage and disclosure of information to prevent unauthorised access. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.
Our Privacy Policy provides you with transparency, confidence and trust that we hold your information secure. The nature of our work means that we respect the confidentiality, and keep secure, any information that you choose to share with us. Your personal data will only be used for processing marketing materials from us if you have given your consent. If you have given us your consent, from time to time, we will send our latest updates to you on the availability of the various programmes and events offered by us. We will not share your data with any other organisation. We do not sell, trade or rent any personal information to others.
Should you wish to unsubscribe at any time you may click the link on any of our emails or let us know by email to hello@michaelnicholas.com.
If you ever have any questions about your agreement with us, then contact Michael Nicholas at michael@michaelnicholas.com.

2. Definitions and interpretations

In this Policy, the following terms shall have the following meanings:
• “Web Site” means www.michaelnicholas.com.
• “Content” means any text, graphics, images, audio, video, software, data compilations and any other form of information capable of being stored in a computer that appears on the Web Site.
• “Cookie” means a small text file placed on your computer by Optimal Track Ltd when you visit certain parts of this Web Site. This allows us to identify recurring visitors and to analyse their browsing habits within the Web Site. Further details are at 11 below “How we Use Cookies”.
• “Data” means collectively all information that you submit to Optimal Track Ltd. This includes information submitted using any of our Services or Systems.
• “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).
• “Service” means collectively any services or information that Optimal Track Ltd makes available through the Web Site or directly with you either now or in the future.
• “System” means any online communications infrastructure that Optimal Track Ltd makes available through the Web Site either now or in the future. This includes, but is not limited to, web-based email and email links.
• “User” / “Users” means any third party that accesses the Web Site and uses our services and is not employed by Optimal Track Ltd and acting in the course of their employment.

3. What we collect

We may collect the following personal data from you when you use our website, attend events, contact us using email, sign up to or purchase a service from us as a client, or provide services to us:
• Your name and title.
• Billing and delivery addresses.
• Contact email addresses.
• Contact telephone numbers (work and mobile).
• Other information given to us for the purpose of communicating or meeting.
• Company name and address.
• Job title.
• The IP address you use to log in.
• Enquiries you have made.
• Your interests, preferences, feedback and survey responses.
• Products (free or otherwise) that you download.
• Transaction data, including details of payments and associated communications, and information about products and services you have purchased.
• Financial information such as bank account and payment card details.
• Marketing data, including your preferences for receiving marketing from us.
• Responses and actions relating to our courses.

4. What we do with the information we collect

The information that we hold is required to understand your needs and provide you with a better service. In particular, it enables us to:
• Respond to enquiries.
• Allow you access to the Optimal Track Ltd website and services.
• Fulfil our obligations arising from any contracts entered into between you and Optimal Track Ltd, and for their general management.
• Organise and deliver Optimal Track Ltd events and training course and fulfil any specific needs you may have.
• Process payments from and to you.
• Maintain Optimal Track Ltd records.
• Provide you with news, insights and updates.
• Invite you to provide feedback on our products and services.
• Invite you to take part in research campaigns.
• Notify you of any changes in our services.
• Monitor how you respond to our communication.
• Allow us to monitor usage statistics as a basis for future improvements to relevant website processes.
• Monitor and improve our products and services.
• Meet security / health and safety requirement where you attend events or training courses.
• Verify your identity.
• Track systems use by user.
• Periodically conduct quality check on the data we hold.
We only use your personal information for our own uses or for companies we work with. We may use your personal information to send you information about third parties which we think you may find interesting.
Special personal information is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. It also includes information about criminal convictions and offences.
We do not collect any special personal information about you.

5. Our lawful bases for processing your information

We will only use your personal information where one of the following applies:
• You have given us your consent, such as to send you marketing communication or information which we feel you may find interesting. You can withdraw your consent at any time by clicking unsubscribe on the link allocated at the bottom of the emails you receive from us.
• It is necessary for performing a contract that we have with you, such a fulfilment of a service for which you have signed up.
• For our own (or third party’s) legitimate interests provided your rights do not override these interests, such as:
o Fraud prevention.
o Sending appropriate and tailored communication to you.
o Monitoring and improving our products and services.
o Enhancing the learning experience (for example tailoring our events / training courses to the audiences attending or sharing information relevant to your attendance at an event we organise.
o Enhancing the networking opportunities that we offer.
o Managing the data we hold.
• We need to comply with a legal obligation.
Your personal information will only be used for the purpose or purposes it was collected. It will not be sold, shared or distribute to third parties unless we have your permission or where it is necessary for one for the reasons listed above.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract. In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

6. Your rights in controlling your personal information

You can ask us to make changes in how your data is handled and we will respond promptly should a request be made.
You have the following rights over the personal data about you that we are holding and processing:
• Right to be informed. This Policy provides you with information in relation to how your data is processed. This ensures that we are transparent about what we will do with the information you supply to us.
• Right of access. You may request details of personal information which we hold about you under the Data Protection Act 2018 and the General Data Protection Regulation. This is called a Subject Access Request.
• Right to request information held is accurate and how to update it. If you believe that any information we are holding on you is incorrect or incomplete, please email us at hello@michaelnicholas.com and we will respond as quickly as possible.
• Right to erasure. In certain circumstances, you may ask us to delete information about you and stop processing or publishing it (often called the Right to be Forgotten).
• Right to object to the processing that is likely to cause you damage or distress. Where you challenge the accuracy or lawful processing of your information, we will consider this.
• Right to receive an electronic copy of any information you have consented to us holding known as data portability. You can ask us to provide the personal data about you we hold, securely and in a machine-readable format, so it can be moved, copied or transferred to be used across different services or for you to give to another organisation.
• Right to object. You can unsubscribe from our mailings and remove your details at any time. If you wish to stop receiving communications from us, you will be able to do so by contacting us at hello@michaelnicholas.com.
If you wish us to remove personally identifiable information from our website, you should contact us to make your request. This may limit the service we can provide to you.

7. How long we store your information

Optimal Track Ltd meets its obligations in holding the data you provide to us. These include complying with any laws and rules that apply to us and to our service providers. We follow clear guidelines to ensure that your data is not held for longer than is necessary to:
• Provide you with the services you have requested.
• Comply with other law, including for the period demanded by our tax authorities.
We hold the information that you provide to us while you are an active, client and / or user of our services.

8. Keeping your information secure

Data security is of great importance to Optimal Track Ltd. In order to prevent unauthorised access or disclosure we have taken care to put in place suitable physical, electronic and managerial procedures in order to safeguard and secure any data collected online. The Optimal Track Ltd. website is maintained on a secure server. All our suppliers and contractors meet the standards we require.
Unfortunately, no data transmission or storage system is completely secure. If you feel that the security of your account or interaction with us have been compromised, please contact us immediately. If such disclosure does occur, we will contact you as soon as possible to explain what has happened and take all steps required of us to meet our obligation under the legislation. For more information, contact us at hello@michaelnicholas.com.

9. Communicating with us

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.

10. Links to other websites

Our website contains links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over those other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to the website in question.
Optimal Track Ltd. may, from time to time, employ the services of other parties to deal with matters including but not limited to:
• Payment handling.
• Search engine facilities.
• Advertising and marketing.
The providers of such services do not have access to certain personal data provided by users of our website.

11. How we use cookies

A ‘cookie’ is a small text file that is stored by the browser on your computer, tablet or mobile phone. Websites are able to read and write these files, allowing them store things such as personalisation details or user preferences. By providing this “memory” for the website, they enable it to recognise a user and respond appropriately.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose.
Optimal Track Ltd. may use ‘cookies’ to receive and store certain details whenever a user interacts with us. Once you agree by clicking the Accept box on the website, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences such as identifying your computer’s previous visits to a website, ascertaining the most popular features of a website or enabling an organisation to present specific information to you.
No information about you is stored in the session cookie. No other forms of cookies are used, nor do we place any code on your computer.
Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our website.

12. Complaints

If you wish to make a complaint about how we have processed your personal information, and we cannot resolve it, then you have the right to lodge a complaint to the Information Commissioner:
The Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.gov.uk

13. Changes to this policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any questions or concerns about our collection, use or disclosure of your personal information, please get in touch via hello@michaelnicholas.com and we’ll be happy to help with your query.

© Optimal Track Ltd.
September 2018