Privacy Policy

Privacy Policy (Updated 16/04/19)

Overview

In order for us to operate our business and provide our services to You, it is sometimes necessary for us to collect or process information about You. In general terms, this information will take one or more of the following forms:

1. Information that you provide to us directly, such as in the situation where you complete an online form or send us a message via our website;
2. Information that is automatically sent to us by Your computer’s internet browser when you visit our website, such as your computer’s technical address (or ‘IP address’) or information about which particular internet browser you are using and so on;
3. Information about how you use our website or our services, such as which pages you visit, how frequently you visit the site and so forth.

This privacy policy sets out the detail of what information we collect, as well as how that data is used and protected.

Our commitment to data privacy

We are fully committed to maintaining the privacy of any information (‘personal data’) that you provide to us. Furthermore, we commit to ensuring that such data is held securely, used appropriately and only retained for as long as is necessary.

Our systems and services are designed with privacy in mind, and we operate a ‘data minimisation’ principle wherever possible – that is to say that we will only ever ask you for the minimum amount of information required to provide our services efficiently; we have no desire to retain (and therefore maintain) any more information than is necessary. We aspire to comply to the fullest extent possible with applicable data protection regulations, in particular the European Union’s General Data Protection Regulation (‘GDPR’) and ePrivacy Directive, where applicable.

Who we are

In terms of your use of this website, We, Phocus Life Ltd, act in the capacity of Data Controller, and should you have any questions or concerns about the data we hold about you, we can be contacted using the information below:

Data Controller: Phocus Life Ltd
Correspondence address: 10 Harley Street, London, W1G 9PF United Kingdom
Email correspondence: info@phocuslife.com

Definition of ‘personal data’

When we refer to ‘personal data’ we mean any information that allows us to identify you personally. Obvious examples include your name, email address, postal address etc. We will always seek to gain your explicit consent to providing this information before we collect it from you, although this may not be the only legal basis on which we collect the data.

Other types of information, such as your computer’s ‘IP’ address or broad geographical location do not, generally, allow us to identify you directly. However, because in their current form, European data privacy regulations are somewhat vague in this regard, we will cover the use of such data here also.

Who we share data with

We operate on a strict ‘need to know’ basis for all data that we work with, and that is particularly true for any personal data. The only people/organisations that are granted access to personal data are:

• Employees of Phocus Life Ltd and their third-party administrative support
• Our web hosting technology suppliers (currently WPengine) who provide the physical server infrastructures that our website(s) operate on.
• Our cloud storage and technology supplier (currently Dropbox) whose services we use for secure backup storage.
• Google –  whom we use for email relay services, advertising, and data analytics
• Leadpages and Drip – whom we use for collection and management of the content that you submit, as well as to deliver information to you by email.
• Paypal – who processes payment information in part through information contained on forms on our site

How your data is protected

We take the security of all personal data very seriously, and that data is protected in a number of ways:

• Access control: access to personal data is strictly limited in line with our policy detailed in the ‘who we share data with section’ on this page. Access is controlled by individual user accounts, where a strong password policy is enforced
• Dedicated security software: We operate dedicated security scanning and access control software on all of our websites. This software is responsible for limiting login attempts to our site, blocking potentially malicious attempts to access our services, and regularly performing full file system scans.
• Data encryption: where data is stored in a cloud facility (such as the storage of website backup files), that data is encrypted both ‘in transit’ and ‘at rest’ – meaning that all data is securely obscured both during the process of transfer to the cloud provider, and then additionally when it is in storage at its final location.This website is also secured with SSL encryption, which means that all traffic to and from our servers is encrypted. This applies to our own administrative access to the website as well as that of users of our services.

Access to your personal data

In the situation where you have directly provided personal information to us (such as by completing an online form or contacting us for further information), you have a number of rights regarding the personal data that we hold:

• You have the right to obtain from us confirmation about whether any such data is being held;
• You have the right to require that we provide you with whatever data we are holding/processing about you, including the right for that data to be transferred to another data controller;
• Even if you have consented to Us processing your personal data, you have the right to withdraw that permission at any time;
• You have the right to require us to rectify any incomplete or incorrect information held about you;
• You have the right to require us to erase the data held about you (the ‘right to be forgotten’);

In the situation where we collect personal data automatically (such as from your internet browser or via internet Cookies or other similar technologies):

• You have the right to object to the legal basis upon which we are collecting this data, and We have an obligation to consider and respond to that objection;
• You have the right to request the prevention of further processing of your data while your objection is considered;
• You have the right to make a complaint to the relevant data protection authority (which, in the UK, is the Information Commissioner’s Office or ‘ICO’)
• In most circumstances, you can exercise these rights without paying a fee to us.

Types of data collected

 Website contact forms

When you complete one of the contact forms on our website to seek an initial assessment session or to receive specific informational content, we will ask you for a number of pieces of personal information, such as your name, email address, phone number and other contact details. This is obviously required for us to respond to your request. This data will only be used to get in touch with you.

If you do not use or submit an online form on the website, no data will be collected in that regard.

Technical data (such as ‘IP address’)

When you visit our website, our systems will log a record of your visit in our server logs, and typically this record will include the technical ‘IP’ address that is associated with your device and the browser type and version that you are using.

Such server logs are extremely common practice, and are used to monitor technical resources, monitor high-level server activity, and importantly to detect and prevent malicious or fraudulent activity on our systems. This data can also be used, if required, to diagnose reports of technical issues. The storage of IP addresses, allow us to identify patterns of behaviour (such as repeated malicious attempts to access a system).

IP addresses, in and of themselves, do not allow us in any way to identify you as an individual, especially given that it is very common for IP addresses to be dynamically allocated by your service provider, and will therefore often routinely change.

Furthermore, we do not and will not use the content of server access logs to attempt to determine an identifiable individual. We therefore do not consider that data held within server logs falls within the scope of ‘personal data’, and accordingly we do not seek your consent to collect it.

Cookies

Cookies allow us to better understand how users are using our website and other related services. They can also be an essential part of providing certain online functionality. They are all essentially small data files placed on your computer (or other device) that allow us to tell when you have visited a particular page, or performed a particular action (such as clicking a particular button) on our website.

These technologies are used by most websites as they provide useful insight into how the services are being used, as well as improving speed, performance and security, and enabling us to improve our personalisation of your experience.

WHAT ARE COOKIES?

These are small text files placed in the memory of your browser or device when you visit a website. Cookies allow a website to recognize a particular device or browser. There are several types of cookies:

• Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
• Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
• First-party cookies are set by the site you are visiting.
• Third-party cookies are set by a third party site separate from the site you are visiting.

There are a number of ways that you can influence how cookies are used on your particular device. Most commercial browsers (such as Chrome, Safari, Edge, Internet Explorer, Firefox etc) allow you to set preferences for whether to allow or block website cookies.

They will also provide tools that allow you to remove any cookies that have already been set. Using the ‘Help’ functionality of your browser, or an internet search, will help you to understand how to use these features for your particular browser.

Website Analytics

We use Google Analytics to better understand what people look at on our website.

When people visit our site, information about their visit (such as which pages they look at, how long they spend on the site and so on) may be sent in an anonymous form to Google Analytics (which is controlled by Google).

The data contains information about anyone who uses our website from your computer, and there is no way to identify individuals from the data.

We ensure that no personally identifiable information is ever contained within the data sent to our analytics providers, and we also perform a process which partially obscures your IP address information.

As analytics information is not personal data, we do not specifically ask for your prior consent.