Privacy Policy

Effective date: 01st July 2021

Jonathan Ralph (“us”, “we”, or “our”) operates the www.jonathanralph.com website (the “Service”) in collaboration with Holborn Wealth Management S.L. (trading as Holborn Assets).

This page sets forth our policies regarding the collection and use (including disclosure) of personal data when you use our Service and the choices you may make in relation to that data.

We use your data to provide and make improvements to the Service. By using the Service, you consent to the collection and use of your personal information as established within this policy. Unless otherwise defined in this present policy, terms used in this Privacy Policy have the same definitions as per Terms and Conditions, accessible via www.jonathanralph.com

 

DEFINITIONS

Service

Service is the www.jonathanralph.com website operated by Jonathan Ralph and in collaboration with Holborn Assets.

Personal Data

Personal Data means data about a human individual who can be identified from those data (or from information that is either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically that may be generated by the use of the Service or from the infrastructure of the Service itself.

Cookies

Cookies are small pieces of data stored on a User’s device that are most commonly used to improve or tailor a user experience.

Data Controller

Data Controller means a person who (either alone or jointly with others) determines the manner in which any personal data are or will be processed.

For the purpose of this Privacy Policy, Jonathan Ralph is a Data Controller of your Personal Data, and may operate in collaboration with, and thereby share data with, Holborn Assets.

Data Processor

Data Processor (the term Service Provider also applies) means any person (excluding employees of the Data Controller) that processes data on behalf of the Data Controller. Holborn Assets is a Data Processor

We may work with multiple Service Providers in order to process your data more efficiently.

Data Subject

Data Subject is any living individual who is the subject of the aforementioned Personal Data.

User

The User is the individual that uses our Service. The User relates to the Data Subject.

 

INFORMATION COLLECTION AND USE

We collect various different types of information for several purposes that include the provision of and improvement of our Service to you.

Types of Data Collected

Personal Data

While using our Service, you may be asked to provide us with certain unique personal information that could be used to either contact or identify you (“Personal Data”). This information may include, but is not limited to:

  • Your email address
  • First name
  • Last name
  • Phone number
  • Full address and other geographic identifiers
  • Cookies
  • Usage Data

We may utilize your Personal Data to communicate with you. This may include email newsletters, marketing communications, promotional materials and other information that may be of interest to you. You may opt out of these communications by following the unsubscribe link provided in the emails sent or, if contacted directly by either Jonathan Ralph or a Data Processor by communicating to us in writing your desire not to be contacted.

Usage Data

We may gather information on how the Service is accessed and used (“Usage Data”). Usage Data may include data such as your computer’s IP address, browser, your activity on our site including pages visited and time spent there, times and dates of your usage sessions, unique device identifiers and any other relevant diagnostic data.

Location Data

We may collect, use and store information about your location if you provide us with consent (“Location Data”). We use this data to provide certain features of our Service, to tailor your Service experience to your circumstances, and to improve your overall user experience.

You can enable/disable location services through your device settings. Please review your device’s operating system for instructions on how to do so.

Tracking & Cookies Data

We may use cookies or similar tracking methods to monitor the activity on our Service and gather/store information.

Cookies may include an unique and anonymous identifier. They are sent to your browser from a website and subsequently stored on your device. Tracking technologies may include beacons, tags, and scripts to gather and monitor information. These are used to analyse our Service and facilitate improvements.

You may request that your browser refuses all cookies. Please bear in mind that if you do not accept cookies then some elements of our Service may be unavailable to you.

Examples of Cookies we may use:

  • Session Cookies. These may be used to operate and run our Service.
  • Preference Cookies.These may be used to remember your setting preferences and improve your experience.
  • Security Cookies.These may be used to keep users and our Service safe, in addition to other security matters.

 

USE OF DATA

Jonathan Ralph utilizes collected data for several purposes included but not limited to the following:

  • Service provision
  • Service maintenance
  • To notify of changes to the Service
  • To provide efficient customer support
  • To improve our Service through data analysis or other method
  • To monitor Service usage
  • To identify, correct or prevent technical issues
  • To send you news, promotions, special offers and information about goods, services and events or other relevant topics that we offer which could be considered similar to those that you have already purchased, booked or made enquiries for unless you have instructed us not to send you such information

 

LEGAL BASIS FOR The PROCESSING of PERSONAL DATA UNDER EU GENERAL DATA PROTECTION REGULATIONs (GDPR)

If you are from the European Economic Area (EEA), Jonathan Ralph’s legal basis for the collection and use of personal information as described in this Privacy Policy depends on the Personal Data we collect and the context in which this data is collected.

Jonathan Ralph may process your Personal Data for the following reasons:

  • To create a contract with you
  • You have given us permission to do so
  • This data processing is in our legitimate interest and is not overridden by your individual or collective rights
  • For the purposes of payment processing
  • To comply with relevant and applicable law(s)

 

RETENTION OF DATA

Jonathan Ralph may retain your Personal Data for as long as is necessary for the reasons set forth in this Privacy Policy. We will retain and utilize your Personal Data to the extent that is required to comply with our own legal obligations (including to comply with applicable laws), to resolve conflicts or disputes, and ensure our legal agreements and policies are enforced.

Jonathan Ralph may also retain your Usage Data for as long as is necessary for the purposes of analysis, improved functionality or enhanced security.

TRANSFER OF DATA

Your information, including your Personal Data, may be sent to and stored on computers located outside of your local area, country or other governmental jurisdiction. Please be advised that data protection laws in these areas may differ than those within your jurisdiction.

Your consent to this Privacy Policy in combination with your submission of information represents your agreement to the transfer of data in this way.

Jonathan Ralph will endeavour to take all reasonable steps to ensure your data is handled securely and in accordance with this Privacy Policy. We will also endeavour to ensure that no transfer of your Personal Data will take place to organizations lacking adequate data and process controls in place.

 

DISCLOSURE OF DATA

In certain situations, Jonathan Ralph may be obligated to disclose your Personal Data by law or concerning valid requests by public authorities.

Legal Requirements

Jonathan Ralph may disclose your Personal Data if we have reason to believe that such action is required to:

  • Comply with a legal requirement
  • Protect or defend the property, interests or rights of Jonathan Ralph
  • Defend against or examine possible wrongdoing in connection with the Service
  • Defend the personal safety of the public or users of the Service
  • Defend us against legal liability

 

SECURITY OF DATA

We value the security of your data. However, it must be remembered that no one method of electronic storage or data transmission via Internet can be guaranteed as being completely secure. While we endeavour to use reasonable means to protect your Personal Data, we cannot promise it will be absolutely secure.

 

YOUR DATA PROTECTION RIGHTS UNDER EU GENERAL DATA PROTECTION REGULATIONs (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights.

Jonathan Ralph endeavours to take reasonable steps to allow you to correct, update, delete, or restrict the use of your Personal Data.

If you would like to be informed about the Personal Data we hold about you and if you wish that it be deleted from our systems, please contact us.

In particular circumstances, you have the data protection rights below:

  • The right to access, update or to delete. Whenever made possible, you may access, update or request that we delete parts of your Personal Data within your account section. If you are not able to carry out these actions, please contact us and we will endeavour to help.
  • The right of rectification. You have the right to update inaccurate or incomplete information.
  • The right to object. You have the right to object to our processing of your Personal Data. If this is the case, please contact us.
  • The right of restriction. You have the right to ask that we limit the processing of your personal information. If this is the case, please contact us.
  • The right to data portability. You have the right to receive a copy of the data that we store in an organised, machine-readable format.
  • The right to withdraw consent. You have the right to remove your consent where Jonathan Ralph relies on your consent to process your personal information. If this is the case, please contact us.

We may ask you to confirm your identity before we answer any such requests.

You have the right to issue a complaint to a Data Protection Authority regarding our collection and utilization of your Personal Data. For further information, contact your local data protection authority.

 

SERVICE PROVIDERS

We may utilize third-party companies and individuals in the provision of our Service (“Service Providers”), to perform the Service on our behalf, to provide Service-related activities or to support us in any analysis of the use of the Service.

Said third parties may have access to your Personal Data in order to carry out these tasks on our behalf. They are required to refrain from disclosure of Personal Data or its utilization for any other purpose.

Analytics

We will utilize third-party Service Providers to analyse the use of our Service and monitor site use.

  • Google Analytics: Google Analytics is a service offered by Google that monitors and provides analysis on website traffic, including the Service. This data may be shared with other Google services. Google may use the data that is collected to adapt and personalize the advertisements of its own network. You may opt out of the monitoring or tracking of your activity on the Service by installing the Google Analytics opt-out browser add-on. This is a browser extension that prevents the Google Analytics JavaScript from sharing data with Google Analytics regarding activity on a website.

For further information regarding Google’s activities, please visit their Privacy & Terms web page: https://policies.google.com/privacy?hl=en

 

Behavioural Remarketing

Jonathan Ralph may use remarketing services to publish advertisements on third-party websites to you after you have visited our web pages. We, and these third parties, may use cookies to tailor advertisements based on your past usage of the Service.

To opt-out, follow Facebook’s instructions: https://www.facebook.com/help/568137493302217

 

You may also opt-out from certain other companies via the Digital Advertising Alliance in the USA (http://www.aboutads.info/choices/), the Digital Advertising Alliance of Canada (http://youradchoices.ca/) or the European Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu/). You may also be able to do this via your mobile device settings.

For further information on the practices of Facebook, please view their Data Policy: https://www.facebook.com/privacy/explanation

 

 

LINKS TO OTHER SITES

Our Service may contain links to other sites that we do not operate. By clicking on such a link, you will be taken to a third-party website. We recommend that you read and review the Privacy Policy of all such sites.

We do not influence or control these sites. We assume no responsibility for their content, practices or privacy policies.

 

CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 16 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

 

CHANGES TO THIS PRIVACY POLICY

We reserve the right to amend and update our Privacy Policy as we deem necessary. We will inform you of any changes by posting the updated Privacy Policy on this webpage.

In the case of significant changes to this document, we will also advise you via email or via a highly-visible notice on our Service. This will be sent/published prior to the change becoming effective. The “effective date” of our Privacy Policy will also be duly updated to indicate the date the amendments have been introduced and therefore taken effect.

We recommend that you review this Privacy Policy from time to time to ensure you are up to date with any changes. All updates and modifications to this Privacy Policy take effect from the moment that they are posted on this webpage.

CONTACT US

For any questions regarding this Privacy Policy, you can contact us: