Last Updated: 02/15/2022
explain how we collect, use, share, and protect the personal information you provide to us
when you access our website, purchase our goods or services, or engage with us on social
media, as well as your own rights to the information we collect.
changing the “last updated” date at the top of this policy. Any changes become effective
immediately upon publication on our website, and you waive specific notice of any changes to
the policy by continuing to use and access our site(s). We encourage you to review this privacy
policy periodically, when you use our website for any purpose or engage with us on social
Carole Nicolaides President of Progressive Leadership, Inc. is the data controller and she is
responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details are:
Carole Nicolaides- President
Email address: firstname.lastname@example.org
It is very important that the information we hold about you is accurate and up to date. Please
let us know if at any time your personal information changes by emailing us at
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND
WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include
anonymized data. We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be
through the contact form on our website, through blog comments on our website, through
email, text, social media messaging, social media posting or any other communication that you
send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this
processing is our legitimate interests which in this case are to reply to communications sent to
us, to keep records and to establish, pursue or defend legal claims.
Customer Data that includes data relating to any purchases of goods and/or services such as
your name, title, billing address, delivery address, email address, phone number, contact
details, purchase details and your card details. We process this data to supply the goods and/or
services you have purchased and to keep records of such transactions. Our lawful ground for
this processing is the performance of a contract between you and us and/or taking steps at
your request to enter into such a contract.
User Data that includes data about how you use our website and any online services together
with any data that you post for publication on our website or through other online services. We
process this data to operate our website and ensure relevant content is provided to you, to
ensure the security of our website, to maintain back- ups of our website and/or databases and
to enable publication and administration of our website, other online services and business.
Our lawful ground for this processing is our legitimate interests which in this case are to enable
us to properly administer our website and our business.
Technical Data that includes data about your use of our website and online services such as
your IP address, your login data, details about your browser, length of visit to pages on our
website, page views and navigation paths, details about the number of times you use our
website, time zone settings and other technology on the devices you use to access our website.
The source of this data is from our analytics tracking system. We process this data to analyze
your use of our website and other online services, to administer and protect our business and
website, to deliver relevant website content and advertisements to you and to understand the
effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests
which in this case are to enable us to properly administer our website and our business and to
grow our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and
our third parties and your communication preferences. We process this data to enable you to
partake in our promotions such as competitions, prize draws and free giveaways, to deliver
relevant website content and advertisements to you and measure or understand the
effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests
which in this case are to study how customers use our products/services, to develop them, to
grow our business and to decide our marketing strategy.
Opt In Data that includes the name and email address you use to opt in to our email newsletter
or sign up for a freebie. We process this data to send you emails about our sales offerings,
newsletters and occasional promotions and special offers. Our lawful ground of processing is
consent and legitimate interest which in this case are to provide our email subscribers with free
value, market our products/services and grow our business.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant
website content and advertisements to you (including Facebook adverts or other display
advertisements) and to measure or understand the effectiveness of the advertising we serve
you. Our lawful ground for this processing is legitimate interests which is to grow our business.
We may also use such data to send other marketing communications to you. Our lawful ground
for this processing is either consent or legitimate interests (namely to grow our business).
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes
details 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. We do not collect any information about criminal convictions and
3. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in
forms on our site or by sending us emails). We may automatically collect certain data from you
as you use our website by using cookies and similar technologies. We may receive data from
third parties like analytics providers such as Google, advertising networks such as Facebook and
providers of technical, payment and delivery services, such as data brokers or aggregators.
4. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is
either your consent or our legitimate interests (namely to grow our business). Under the
Privacy and Electronic Communications Regulations, we may send you marketing
communications from us if (i) you made a purchase or asked for information from us about our
goods or services or (ii) you agreed to receive marketing communications and in each case you
have not opted out of receiving such communications since. Under these regulations, if you are
a limited company, we may send you marketing emails without your consent. However you can
still opt out of receiving marketing emails from us at any time. Before we share your personal
data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by following
the opt-out links on any marketing message sent to you or by emailing us at
email@example.com at any time. If you opt out of receiving marketing
communications this opt-out does not apply to personal data provided as a result of other
transactions, such as purchases, warranty registrations etc.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
a. Service providers who provide IT and system administration services.
b. Professional advisers including lawyers, bankers, auditors and insurers
c. Government bodies that require us to report processing activities.
d. Third parties to whom we sell, transfer, or merge parts of our business or our assets.
e. Payment processors that handle your payments for our goods or services.
f. Newsletter service providers that allow us to send you marketing emails.
g. Countdown timer tools who use your IP address to customise countdown timers in our
We require all third parties to whom we transfer your data to respect the security of your
personal data and to treat it in accordance with the law. We only allow such third parties to
process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL DATA
Our website is hosted by servers located in the U.S. Therefore, if you reside in the European
Union, some of your data will be transferred internationally to those servers. Transfers will be
protected by appropriate safeguards, namely the EU-US Privacy Shield. More information on
the Privacy Shield can be found at: https://www.privacyshield.gov/welcome
7. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally
lost, used, altered, disclosed, or accessed without authorization. We also allow access to your
personal data only to those employees and partners who have a business need to know such
data. They will only process your personal data on our instructions and they must keep it
confidential. We have procedures in place to deal with any suspected personal data breach and
will notify you and any applicable regulator of a breach if we are legally required to
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements. When deciding what the correct time is to keep the data for we look at its
amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the
processing purposes, if these can be achieved by other means and legal requirements.
9. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the
right to request access, correction, erasure, restriction, transfer, to object to processing, to
portability of data and (where the lawful ground of processing is consent) to withdraw consent.
If you wish to exercise any of the rights set out above, please email us at
firstname.lastname@example.org. You will not have to pay a fee to access your personal data
(or to exercise any of the other rights). However, we may charge a reasonable fee if your
request is clearly unfounded, repetitive or excessive or refuse to comply with your request in
We may need to request specific information from you to help us confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person who has no right
to receive it. We may also contact you to ask you for further information in relation to your
request to speed up our response.
10. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on
those links or enabling those connections may allow third parties to collect or share data about
you. We do not control these third-party websites and are not responsible for their privacy
statements. When you leave our website, we encourage you to read the privacy notice of every
website you visit.
You can set your browser to refuse all or some browser cookies, or to alert you when websites
website may become inaccessible or not function properly.
the internet, around the world. We cannot prevent the use or misuse of your data by other
parties. In the unlikely event customer data has been lost, stolen, or potentially compromised,
our policy is to alert our customers via email no later than 72 hours of our company becoming
aware of the event. We will also report such incident to any required data protection authority.
We will work closely with any customers affected to determine next steps such as any end-user
notifications, needed patches, and how to avoid any similar event in the future.