PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING OUR SITE
WHO DOES THIS POLICY APPLY TO?
This privacy policy applies to people who:
• visit www.butterflyeffectguru.com;
• make an enquiry about Butterfly Effects programmes or services;
• request information from us; and/or
• download or purchase a publication.

This policy does not apply to people who book on one of Butterfly Effects programmes, events or webinars (including when you voluntarily complete customer surveys or provide feedback to us in relation thereto).

ABOUT THIS POLICY
This privacy policy (this Policy) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. By using www.butterflyeffectguru.com, you accept the practices described in this Policy. We may amend this Policy at any time, and whenever we do so we will notify you by posting a revised version on our Site. Please review this Policy each time you visit our Site as it may have been updated since your last visit.

VISITORS TO OUR SITE
Personal information we collect: With regard to each of your visits to our Site, we will automatically collect:
• technical information, including the Internet Protocol (IP) address used to facilitate your connection to the Internet, browser type and version, time zone setting, browser plug-in types and versions, hardware information.
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); services, products, publications and articles you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and referring sites

Cookies: Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of our Site and to compile statistical reports on website activity. You can enable or disable cookies by modifying the settings in your browser. You can find out how to do this, and find more information on cookies, at www.allaboutcookies.org.

Using your personal information: We will use this information for the following legitimate interests:
• to maintain our Site and keep it safe and secure;
• to protect the rights, property or safety of Butterfly Effect LLP, our clients, suppliers, contacts or others (we will also use your information where we are required by law to do so);
• to improve our Site and ensure that content is presented in the most effective manner for you and for your device(s);
• for internal operations (including troubleshooting, data analysis, testing, research, and statistical and survey purposes);
• to measure or understand the effectiveness of our Site and/or any marketing we serve to you and others, and to deliver relevant marketing to you;
• to deal with any issues you have reported with our Site and

Sharing your personal information: We will only share personal information with third parties in the following instances:
• contractors and agents (but their use shall be limited to the performance of their duties and in line with the reason for processing);
• with analytics and search engine providers that assist us in the improvement and optimisation of our Site; and
• our website hosting supplier, WordPress to enable them to maintain and host our Site.

Retaining your personal information: This information is kept for one year and will then be deleted automatically. However:
• if we are required by law to retain it for longer, we will retain it for the required period; and/or
• where the information is being used in connection with legal proceedings (including prospective legal proceedings) it will be retained for the duration of those legal (and any enforcement) proceedings.

Your rights: Please see Your rights below.

MAKING ENQUIRIES, REQUESTING INFORMATION AND DOWNLOAD/PURCHASING A PUBLICATION
Personal information we collect: If you contact us or we contact you (by phone, email or otherwise) to:
• make an enquiry about our programmes or services;
• request information from us; and/or
• download or purchase a publication, we will hold your name, contact details and any other details you give us (such as the details you complete if you use a form on our Site to contact us).

(This service will come in the future) If you purchase a publication online your card information is not held by us, it is collected by our third party payment processor – Paypal – who specialise in the secure online capture and processing of credit/debit card transactions.
We don’t record calls.

Using your personal information: We will use this information for the following legitimate interests (whether ours or a third party’s):
• respond to your enquiry about our programmes or services
• provide you with the information you have requested from us and that we think might be of interest to you (e.g., invitations to participate in research studies or events); and/or
• enable you to download, or provide you with, a publication you have requested.

Sharing your personal information: We will only share personal information with third parties in the following instances:
• our contractors and agents (but their use shall be limited to the performance of their duties and in line with the reason for processing);
• where we are required by law to do so; and/or
• with our telephony supplier (which would get to see phone numbers if we call you) and our broadband supplier (which could see email addresses (but not the content of what you send us, if you encrypt it).

Retaining your personal information: This information will be kept for the duration of your enquiry and up to two years thereafter. However:
• if we are required by law to retain it for longer, we will retain it for the required period; and/or
• where the information is being used in connection with legal proceedings (including prospective legal proceedings) it will be retained for the duration of those legal (and any enforcement) proceedings.

Your rights: Please see Your rights below.  If you have also visited our Site, please see Visitors to our Site above.

TRANSFERRING PERSONAL INFORMATION OUTSIDE THE EEA
We share your personal information within Butterfly Effect LLP and to the external third parties (the categories of which are referred to in this Policy). This may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal information out of the EEA, we will ensure a similar degree of protection is afforded to it. In some instances, your personal information may be transferred to countries that have been deemed to provide an adequate level of protection for personal information by the European

Commission. In other instances, we will ensure at least one of the lawful safeguards are implemented, which may include:
• Where we transfer personal information within Butterfly Effect LLP and to certain external third parties, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe; or
• Where we use external third parties based in the US, we may transfer personal information to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal information shared between Europe and the US.

YOUR RIGHTS
In relation to personal information we hold about you, you have the right to:
• get access to your personal information that we hold and receive information about our processing of it;
• ask us to correct the record of your personal information maintained by us if it is inaccurate or to complete incomplete personal information;
• ask us, in certain instances, to erase your personal information or cease processing;
• object to us processing your personal information for direct marketing purposes (see Direct Marketing below);
• challenge us processing your personal information which has been justified on the basis of our legitimate interests;
• ask us, in certain instances, to restrict processing personal information to merely storing;
• ask us, in certain limited instances, to transfer your personal information to another online provider;
• request a copy of an agreement under which your personal information is transferred outside of the EEA;
• prevent processing that is likely to cause damage or distress to you and seek compensation from us for any damages caused to you by us breaching DP Laws;
• be notified of a personal data breach which is likely to result in high risk to your rights and freedoms; and
• complain to the ICO if you believe we have breached DP Laws (please contact the ICO via ico.gov.uk).

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you would like to exercise any of these rights, please contact via the contact page at www.butterflyeffectguru.com or write to us at Butterfly Effect LLP, 71-75 Shelton Street, London, WC2H 9JQ (we may ask you to verify your identity – please cooperate with us in our efforts to verify your identity). Please note that we may need certain personal information to enable us to provide the services and/or information you ask for, so changes you make to your preferences, or restrictions you ask us to make on how we use personal information, may affect what information we can provide.

HOW WE PROTECT YOUR PERSONAL INFORMATION
To help protect the privacy of personal information you transmit, we maintain physical, technical and administrative safeguards. and require the same of any third parties we share your personal information with. We update and test our security technology on an ongoing basis. In addition, we train our staff about the importance of confidentiality and maintaining the privacy and security of your personal information. However, as you will be aware the transmission of information via the internet isn’t completely secure. Although we will do our best to protect your personal information, we can’t guarantee the security of your personal information transmitted to our Site; any transmission is at your own risk. Once we have received your personal information, we will use reasonable procedures and security features to try to prevent unauthorised access.

DIRECT MARKETING
You have a choice about whether or not you wish to receive direct marketing communications from us. If you want to receive direct marketing communications from us about our programmes, research and related services, then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information. We will not contact you for marketing purposes by email, phone or post unless you have given your prior consent.

You can also exercise your right not to be sent direct marketing communications from us at any time by carrying out ‘unsubscribe’ actions which are made available to you (such as clicking on the ‘unsubscribe’ link in each marketing communication email we send you). You can also change your marketing preferences at any time by emailing claire@butterflyeffectguru.com or telephone on +44(0)7435 859066.
We will not share your personal information with third parties for marketing purposes.

LINKS TO THIRD PARTY WEBSITES
Our Site may, from time to time, contain links to and from the websites of third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we don’t accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

Our Site uses interfaces with social media sites such as Facebook, LinkedIn, Twitter and others. If you choose to “like” or share information from our Site through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your Site visit to your personal information.