Privacy Policy and Earning Disclaimer
Last Updated on July 17th, 2015
Antonio Falco Ltd is a business consultancy offering management, training and advisory services primarily but not exclusively relating to sales, sales development, business development, people management, sales people management.
We are a business to business provider working primarily but not exclusively with UK, European and North American based customers, distributions, resellers directly and in-directly. We do not provide services to consumer customers.
Whilst we do not offer services to the general public and consumers but to businesses, the personal data that we have access to, use and keep is related to the business that the individual is connected to and is listed within the content of this policy.
We care about your privacy and this policy is intended to explain what personal data we may collect about you and where we may obtain your data.
This policy is under regular review. Please check for any policy updates.
Personal information that we may process
Contact information: full name, email addresses, phone numbers, associated company, company address.
Current Job role, previous company/job role
Contact history (including emails)
Purchase history (including quotes, orders, invoices)
Marketing subscriptions/preferences/consent (including opt outs, unsubscribes, revoked consent) • Activity on our website (such as pages visited, session length)
IP address used to access our website
Contracts (therefore signatures)
CVs (on occasion we may be sent, asked to review CVs from clients and/or unsolicited sources
Response to marketing campaigns (such as email opens, clicks within emails)
Product use details (including performance data) We do not currently record the audio of telephone calls, but we may have a log of when you called, call length, who you spoke to, and what the subject of that call was.
How we collect information
We may obtain information about you in the following forms and methods:-
You visit our website
You engage with us on social media of which these could be a variety of sources that we may or not be engaged with ourselves
You contact us (via our website that have our contact details available to view these being, email, phone call, conversation) about products or services
You subscribe to receive our newsletter(s) and other forms of communication media
You use our services and or have used our services
You contact us requesting our services
You request a meeting
You are a paying customer
You are a person we collaborate with, partner, or are a prospective business partner
You intentionally give us your business contact information or make your business contact information available, for example at a networking event, an industry event, a meeting or third party introduction
You share information with us in some other format e.g – mail.
From time to time we may purchase a database of business contacts based on a set criteria which may include geography, turnover, employee numbers, contact details, key contact name and legitimate interest as determined by past customers, experience, knowledge, market sectors.
We will only use a legitimate, recognised database provider with policies that fall in line with current legislation.
Databases
We hold several databases in the following formats:-
Excel; over the years we have collected and created databases in the form of Excel spreadsheets of contacts as a result of, business cards received, personal contacts and encounters, business networking events, business events, exhibitions, referrals, introductions, business clubs, speaking engagements, purchase of databases (as described) and direct in-coming contacts due to website, mail, email, texts, social media and telephone calls. These databases are held on a separate external hard drive. These are periodically reviewed, assessed and will be deleted if no longer valid due to no longer failing in line with the business needs, client profile, age and validity of the information.
Current prospective customers; data consisting of business contact details – name, position, address, telephone number, mobile number, email address, social media details, is kept to the point where they become customers or both parties determine that there is no prospect of this happening. Some of these details are kept on an excel spreadsheet as well as in written format this being a carry handheld organiser.
Current customers; data consisting of business contact details – name, position, address, telephone number, mobile number, email address, social media details. In addition contracts, proposals, invoicing details are kept and used on an on-going basis for the fulfilment of the contract and service being delivered. Some of these details are kept on an excel spreadsheet as well as in written format this being a carry handheld organiser.
Past prospective customers; some of these have been deleted, some reside on the Excel databases as described. The normal course of business is that many prospective customers can take several years to come to fruition and this can be substantiated with both the current set of customers and past.
Past customers; these reside on a database (as described) the normal course of business has shown that a percentage of customers do return for continued services from time to time and that this data is vital to the performance and future security of the business. From time to time it may be decided that it is no longer valid and will be deleted.
Newsletter; an external supplier is used to distribute our periodical newsletter. This well-known supplier used by numerous businesses worldwide has a policy in place to hold databases within the EU. However, it is known that they have and do hold databases outside of the EU and we may be subject to that. Since the inception of our newsletters, recipients have only been those invited to receive it. The option to unsubscribe has always ben available and we have taken immediate action when those wishing to unsubscribed have requested to do so. A basic record of unsubscribes is kept.
Mobile phone; a list of business contacts as well as private friends and family details are held on mobile devices.
Email; a list of contacts are held with the email programme used, many of these are automatically added by the software.
Cerebral; a database of contacts and contact details are held within the brain of the key director of the company.
Security
We have put in place appropriate security measures to prevent your data from being accessed in an unauthorised way, altered or disclosed.
We do not share data with third parties for marketing purposes.
We do not share data with third parties unless agreed and this would only be for the purposes of introduction, partnership, mutual interest of parties involved.
PC; access is protected by password
External drive; access is protected by password
Mobile phone; access protected by pin number
Cerebral; all efforts are made to secure the data held by the key director. In case of personal attack, or kidnap, all efforts will be made to resist efforts to entice, blackmail, coerce or torture in order to gain access to the data.
Marketing
As stated we operate solely in a Business-to-Business capacity, our marketing communications are sent to professional email addresses and consist of relevant, informative business news and are only to those invited recipients. We send these emails as a Legitimate Interest, and in all of them, there is an obvious and simple way of opting out of such messages in the future. This opt-out is automatic and is registered immediately.
In addition, marketing information is sent prospective customers on a Legitimate Interest basis to a set of criteria already described.
Your data rights
If we hold any personal information about you, then you are entitled to certain data rights. You have the following rights:
The right to be informed
The right of access 3. The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision making and profiling. You can read more about these rights here – https://ico.org.uk/for-organisations/guide-to-the-general-dataprotection-regulation-gdpr/individual-rights/
For further information, queries, questions, requests please contact us – details at the end:
If you still have questions or complaints about your data privacy, you have a right to contact or report a concern to the UK’s data privacy supervisory authority, the Information Commissioner’s Office – https://ico.org.uk/global/contact-us/
Antonio Falco Ltd is a private limited company registration: No. 4053535, registered at:
Email: enquiries@antoniofalco.com
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