Privacy Policy

This Privacy Policy describes, among other things, the types of information we collect from visitors, our legal basis for collecting it, how long we keep it, what we do with it, and what your rights are about it. For your convenience, it also includes links to our Cookie Policy and Website Terms of Use. By visiting this website, requesting representation, and engaging our services, you kindly agree to the terms of these three policies.

Purpose

The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:

– The personal data we will collect;

– Use of collected data;

– Who has access to the data collected; and

– The rights of Site users.

This Privacy Policy applies in addition to the Terms and Conditions of our Site.

GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

Consent

By using our Site users agree that they consent to:

– The conditions set out in this Privacy Policy.

– When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

You can withdraw your consent by: Contacting the Data Protection Officer, contact details for whom can be found at the foot of this page.

Legal Basis for Processing

We collect and process personal data about users only when we have a legal basis for doing so under Article 6 of the GDPR. We rely on the following legal bases to collect and process the personal data of users in the EU:

– Users have provided their consent to the processing of their data for one or more specific purposes; and

– Processing of user personal data is necessary for us to take, at the request of a user, steps before entering a contract or for the performance of a contract to which a user is a party. If a user does not provide the personal data necessary to perform a contract the consequences are as follows: We cannot respond to your enquiry or, in the case of a media request, provide you with review copies of Elixir.

Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected Automatically

When you visit and use our Site, we may automatically collect and store the following information:

– IP address;

– Location; and

– Content viewed/site behaviour.

Further information about automatic data collection can be found in our Cookie Policy.

Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site:

– First and last name; and

– Email address.

This data may be collected using the following methods:

Contact form completion.

How We Use Personal Data

Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy. The data we collect automatically is used for the following purposes:

– On-site user behaviour.

The data we collect when the user performs certain functions may be used for the following purposes:

– Responding to enquiries.

Who We Share Personal Data With

– Employees and associates. If you use the contact forms to request a copy of Elixir or for media requests about Phil Cleary, your personal data may also be shared with Palamedes PR, our public relations agency, whose Privacy Policy can be found here.

– We may also disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:

– If the law requires it;

– If it is required for any legal proceeding;

– To prove or protect our legal rights; and

– To buyers or potential buyers of this company in the event that we seek to sell the company.

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

How Long We Store Personal Data

User data will be stored until the purpose the data was collected for has been achieved. You will be notified if your data is kept for longer than this period.

How We Protect Your Personal Data

In order to protect your security, we use strong browser encryption and store all of the personal data we collect through enquiries on the PhilCleary.com website on servers in secure facilities. All personal data is only accessible to those who run and manage this website. While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

Your Rights as a User

Under the GDPR, you have the following rights:

– Right to be informed;

– Right of access;

– Right to rectification;

– Right to erasure;

– Right to restrict processing;

– Right to data portability; and

– Right to object.

Children

We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our data protection officer.

How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our data protection officer:

Phil Cleary

phil@philcleary.com

How to Opt-Out of Data Collection, Use or Disclosure

In addition to the method(s) described in the How to Access, Modify, Delete, or Challenge the Data Collected section above, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below: you can opt out of cookies being collected. You can opt-out by users of the website can deny the collection of cookies at the click of a button when they first access the website.

Modifications

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

Complaints

If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the Information Commissioner’s Office in the UK.

Contact Information

If you have any questions, concerns or complaints, you can contact our data protection officer, Phil Cleary, at:

phil@philcleary.com

This Privacy Policy was last updated on 5/12/2023