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Introduction

My name is Pawel Hajdan (“I”, “me” or “my”).

Welcome to the privacy policy for my website pawelhajdan.com (“Website”).

This privacy policy also describes how I handle and protect your personal data when providing you with my services.

I own and operate the Website. I am a sole trader, and my main mail and trading address is:

Pawel Hajdan, 27 Old Gloucester Street, London WC1N 3AX, United Kingdom

1. Important information and about me

It is important that you read this privacy policy together with any other privacy policy or fair processing policy I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data.

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Controller

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I am the controller responsible for your personal data.

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If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. 

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Contact details

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Full name: Pawel Hajdan

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Email address: info@pawelhajdan.com

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Postal address: Pawel Hajdan, 27 Old Gloucester Street, London WC1N 3AX, United Kingdom

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You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). If you are based outside of the UK, you may be able to bring complaints to the data protection regulator of your jurisdiction. I would, however, appreciate the chance to deal with your concerns before you approach the ICO and/or any other regulator so please contact me in the first instance.

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Changes to the privacy policy and your duty to inform me of changes

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This version was last updated on 15 Jan 2024.

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Please keep me informed if your personal data changes during your relationship with me.

2. The data I collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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I may collect, use, store and transfer different kinds of personal data about you which I have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of services you have purchased from me.

  • Technical Data includes data about you use of my website and online services such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website. 

  • Usage Data includes information about how you use the Website and my services. 

  • Marketing and Communications Data includes your preferences in receiving marketing information from me and your communication preferences.
     

If you fail to provide personal data
 

Where I need to collect personal data by law, or under the terms of a contract I have with you, and you fail to provide that data when requested, I may not be able to perform the contract I have or am trying to enter into with you (for example, to provide you with services). In this case, I may have to cancel a service you have with me but I will notify you if this is the case at the time. 

3. How is your personal data collected

I use different methods to collect data from and about you including through:

  • Direct interactions. You may give me your Identity Data and Contact Data by filling in forms or by corresponding with me by post, phone, email or otherwise. 

  • Automated technologies or interactions. As you interact with my website, I will automatically collect Technical Data about your equipment, browsing actions and patterns. I collect this personal data by using cookies, server logs and other similar technologies. 

4. How I use your personal data

I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:

  • Where I need to perform the contract I am about to enter into or have entered into with you.

  • Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where I need to comply with a legal obligation.
     

Purposes for which I will use your personal data
 

I have set out below, in a table format, a description of all the ways I plan to use your personal data, and which of the legal bases I rely on to do so. I have also identified what my legitimate interests are where appropriate.

 

Cookies

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The Website uses cookies. Please refer to my Cookie Policy (https://www.wix.com/about/cookie-policy) for more information about the cookies you use and how you can opt-out from them when visiting the Website.

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Change of purpose

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I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me. 

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If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.

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Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

I may share your personal data with the parties set out below for the purposes set out in the table above.

  • External Third Parties as set out below.

  • Service providers who provide IT and system administration services.

  • Government bodies that require me to report processing activities.  

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions. 

6. International transfers

I do not transfer your personal data outside the UK other than as set out below. 

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Like most businesses, I use software to support my operations, like when I use Google Meet to hold a virtual meeting with you. Your personal data may therefore be transferred out of the UK. 

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I may not always take my meetings within the UK, and in the future I could relocate my usual place of business to another country. The administrative and support services I may use now and in the future may also be located outside the UK. 

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Whenever I transfer your personal data out of the UK, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.  

  • Where I use certain service providers, I may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. 
     

Please contact me if you want further information on the specific mechanism used by me when transferring your personal data out of the UK.

7. Data security

I have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, I limit access to your personal data to those contractors and other third parties who have a business need to know such data. They will only process your personal data on my instructions and they are subject to a duty of confidentiality. 
 

I have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where I am legally required to do so.

8. Data retention

I will only retain your personal data for as long as reasonably necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. I may retain your personal data for a longer period in the event of a complaint or if I reasonably believe there is a prospect of litigation in respect to my relationship with you.

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To determine the appropriate retention period for personal data, I consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which I process your personal data and whether I can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

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In some circumstances you can ask me to delete your data: see your legal rights below for further information.

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In some circumstances I will anonymise your personal data (so that it can no longer be associated with you) for statistical purposes, in which case I may use this information indefinitely without further notice to you. 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

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Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.

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Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to me.

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Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.

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Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: 

  • If you want me to establish the data's accuracy.

  • Where my use of the data is unlawful but you do not want me to erase it.

  • Where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims. 

  • You have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.

 

Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you. 

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Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain services to you. I will advise you if this is the case at the time you withdraw your consent.

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If you wish to exercise any of the rights set out above, please contact me.

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No fee usually required

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

What I may need from you
 

I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.

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Time limit to respond 

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I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated. 

10. Glossary

Comply with a legal, regulatory, tax, accounting or other requirements means processing your personal data where it is necessary for compliance with a legal, regulatory, tax, accounting or other requirements that I am subject to.

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Legitimate Interest means the interest of my business in conducting and managing my business to enable me to give you the best service and the best and most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). You can obtain further information about how I assess my legitimate interests against any potential impact on you in respect of specific activities by contacting me.

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Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

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Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that I am subject to.

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External Third Parties

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  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

  • wix.com for the website

  • hey.com for email

  • Calendly for booking appointments

  • Google Calendar for keeping track of appointments and events

  • Stripe for processing payments

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