Effective Date: 21 July 2024
Welcome to The Andonia Group LTD’s Privacy Policy. The Andonia Group LTD (Trading as Eugénie Michael Legal Services) and its affiliates (“Eugénie Michael”) are firmly committed to protecting your privacy. This Privacy Policy (“Policy”) sets out how Eugénie Michael uses and protects your personal information when you access, visit and use this website or our Services (regardless of where you visit it from) to the extent Eugénie Michael is the data controller of your personal information. Please use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.
2.1 Purpose of this Privacy Policy.
This Privacy Policy aims to give you information on how Eugénie Michael collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or purchase/use a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.
2.1 Who we are
Eugénie Michael will be responsible for your personal data (collectively referred to as “we”, “us” or “our” in this Privacy Policy).
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights please contact us using the details set out below.
2.2 Controller
Eugénie Michael is the controller and is responsible for your personal data (collectively referred to as “Eugénie Michael”, “Company”, “we”, “us” or “our” in this privacy policy). Eugénie Michael has several subsidiaries as listed in the subprocessor list below. This privacy policy is issued on behalf of Eugénie Michael’s group of companies so when we mention “Eugénie Michael”, “Company”, “we”, “us” or “our” in this privacy policy, we are referring to any of the relevant companies in the Company Group responsible for processing your data. Eugénie Michael is the controller and responsible for this website.If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact Eugénie Michael using the details set out below.
2.2 Contact details
Our full details are:
The Andonia Group LTD (Trading as Eugénie Michael Legal Services)
Suite 3440, Unit 3A
34-35 Hatton Garden
London, United Kingdom
EC1N 8DX
By email: info@eugeniemichael.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact Eugénie Michael at info@eugeniemichael.com and we will respond to your request in the first instance.
2.3 Changes to the Privacy Policy and your duty to inform us of changes
2.3.1 The personal data we hold about you must be accurate and current.
Please keep us informed if your personal data changes during your relationship with us.
2.3.1 Eugénie Michael may occasionally update this Privacy Policy.
When it does, Eugénie Michael will also revise the Effective Date at the top of this Policy. Eugénie Michael encourages you to periodically review this Policy to stay informed about Eugénie Michael’s collection, use, and disclosure of personal information. Eugénie Michael reserves the right, at its discretion, to change, modify, add, or remove portions of the Policy at any time.
2.4 Third-party links
2.4.1 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 Policy of every website you visit.
3.1 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).
3.2 We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
3.5 If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
4.1 We use different methods to collect data from and about you including through:
4.1.1 Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
4.1.2 Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
4.1.3 Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources, as set out below:Technical Data from the following
4.1.4 Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
4.1.5 Identity and Contact Data from data brokers or aggregators based inside and outside the UK.
4.1.6 Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
5.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
5.2 Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
5.3 Purposes for which we will use your personal data
5.3.1 Marketing
5.3.2 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
5.3.3 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact Eugénie Michael at info@eugeniemichael.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer |
|
Performance of a contract with you |
To process and deliver your order including:
|
|
|
To manage our relationship with you which will include:
|
|
|
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
|
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
|
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
|
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
|
Necessary for our legitimate interests (to develop our products/services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising.
5.3.4 Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we
think you may want or need, or what may be of interest to you. This is how we decide which
products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or
purchased goods or services from us or if you provided us with your details when you entered a
competition or registered for a promotion and, in each case, you have not opted out of receiving
that marketing.
5.3.5 Third-party marketing
We will get your express opt-in consent before we share your personal data with any company
outside the Eugénie Michael group of companies for marketing purposes.
5.4 Opting out
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 contacting us at any time.
5.5 Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites
set or access cookies. If you disable or refuse cookies, please note that some parts of this
website may become inaccessible or not function properly.
5.6 Change of purpose
5.6.1 We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we 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 Eugénie Michael at
info@eugeniemichael.com and we will respond to your request promptly.
5.6.2 If we need to use your personal data for an unrelated purpose, we will notify you and we
will explain the legal basis which allows us to do so. Please note that we may process your
personal data without your knowledge or consent, in compliance with the above rules, where this
is required or permitted by law.
6.1 We may have to share your personal data with the parties set out below for the purposes set
out in the table in section 5 above.
6.2 We require all third parties to respect the security of your personal data and to treat it
in accordance with the law. We do not allow our 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 our instructions.
7.1 Eugénie Michael is a global business headquartered in the United Kingdom. Personal
information collected by Eugénie Michael worldwide (including in Europe) may be transferred to
the United States or anywhere else where our affiliates, third party service providers and
partners operate. However, Eugénie Michael has taken appropriate safeguards to ensure that your
personal information remains protected in accordance with this Policy and applicable data
protection law. This includes implementing the European Commission’s Standard Contractual
Clauses for transfers of personal information to our affiliates, third-party service providers
and partners.
7.2 If transfers outside of the UK occur: we ensure your personal data is protected by requiring
all our group companies to follow the same rules when processing your personal data. Some of our
external third parties are based outside the UK so their processing of your personal data will
involve a transfer of data outside the UK.
7.3 Whenever we transfer your personal data out of the UK, we ensure a high degree of protection
is afforded to it by ensuring at least one of the following safeguards is implemented:
7.4 Subprocessors
| Name | Processing Activities | Location(s) of Processing |
|---|---|---|
| Google LLC |
Email hosting, collaboration, and analytics (traffic/event analysis), customer support and storage |
Europe |
| Stripe Payments UK Limited | Payment processing including billing and invoicing and customer support | Europe |
| ConvertKit | Customer engagement and relationship management | Europe |
Please contact Eugénie Michael at info@eugeniemichael.com if you want further information on the
specific mechanism used by us when transferring your personal data out of the UK.
8.1 We 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,
we limit access to your personal data to those employees, agents, contractors and other third
parties who have a business need to know. They will only process your personal data on our
instructions and they are subject to a duty of confidentiality.
8.2 Eugénie Michael takes reasonable precautions to protect your personal information from loss,
misuse and unauthorised access, disclosure, alteration, and destruction. No method of
transmission over the Internet, or method of electronic storage is 100% secure, however.
Therefore, Eugénie Michael cannot guarantee its absolute security. We 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 we are legally required to do so.
9.1 How long will you use my personal data for?
9.1.1 We will only retain your personal data for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.
9.1.2 To determine the appropriate retention period for personal data, we 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 we process your personal data and
whether we can achieve those purposes through other means, and the applicable legal
requirements.
9.1.3 By law, we have to keep basic information (provided it is required legally) about our
customers (including Contact, Identity, and Transaction Data) for six years after they cease
being customers for tax and regulatory purposes. In some circumstances you can ask us to delete
your data: see Request erasure below for further information.
9.1.4 In some circumstances we may anonymise your personal data (so that it can no longer be
associated with you) for research or statistical purposes in which case we may use this
information indefinitely without further notice to you.
9.1.5 When Eugénie Michael has no ongoing legitimate business need to process personal
information, we will either delete or anonymise/de-identify it or, if this is not possible (for
example, because the data has been stored in backup archives), Eugénie Michael will securely
store the personal information and isolate it from any further processing until deletion is
possible.
10.1 Eugénie Michael does not control and cannot be responsible for third-party websites’
content, operation, or privacy policies and other terms of service. Eugénie Michael is not
responsible for the protection and privacy of any information which you provide while visiting
such websites and such websites are not governed by this Policy.
11.1 Our Services and Sites are not intended for use by anyone under the age of 16. Eugénie
Michael does not knowingly collect personal data from anyone under the age of 16. If you are
under 16, you may not attempt to register for our Services or send any information about
yourself to us, including your name, address, telephone number, or email address. If we become
aware that we have collected personal data from someone under the age of 16 without verification
of parental consent, we will delete that information promptly. If you are a parent or legal
guardian of a child under 16 and believe that a child has provided us with their personal data,
please contact us at the email or mailing address provided at the end of this Privacy Policy.
12.1 Under certain circumstances, you may have the following rights under data protection laws
in relation to your personal data.
12.1.2 If you wish to exercise any of the rights set out above, please contact Eugénie Michael
at info@eugeniemichael.com and we will respond to your request promptly.
12.3 No fee usually required
12.3.1 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. Alternatively, we may refuse to comply with your request in these
circumstances.
12.4 What we may need from you
12.4.1 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.
12.5 Time limit to respond
12.5.1 We try to respond to all legitimate requests within one month. Occasionally it may take
us longer than a month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.
1 Our Global Privacy Policy applies to all California residents. The following additional
California-specific disclosures are required by California law and relate to both our online and
offline practices for handling “Personal Information” (as defined below) of California
residents.
1.2 The California Consumer Privacy Act (CCPA) regulates the processing of Personal Information,
which is defined as “information that identifies, relates to, is reasonably capable of being
associated with, or could reasonably be linked, directly or indirectly with a particular
consumer or household.” For purposes of honoring the rights of California residents, all
references to PII or Personal Data in our Global Privacy Policy include personal information as
defined in the CCPA.
1.3 For purposes of this section, “Personal Information” has the meaning given in the California
Consumer Privacy Act (“CCPA”), the California Privacy Rights Act of 2020 (“CPRA”), and any
regulations promulgated under either law, in each case, as amended from time to time.
This Section 1 does not apply to;
2. Your Rights
2.1 You have the following rights:
3. How to exercise your rights
3.1 Right to Information/Know, Access, Correction, and Deletion. You can exercise any of the
above rights by emailing us at info@eugeniemichael.com
3.2 Verification of Identity. We will need to verify your identity to process your
information/know, access, correction, and deletion requests and reserve the right to confirm
your California residency. To verify your identity, we may require you to provide government
identification, give a declaration as to your identity under penalty of perjury, and/or provide
additional information. These rights are not absolute, and in some instances, we may decline
your request as permitted by law.
3.3 Authorised Agents. Your authorized agent may make a request on your behalf upon our
verification of the agent’s identity and our receipt of a copy of the valid power of attorney
given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you
have not provided your agent with such a power of attorney, you must provide your agent with
written and signed permission to exercise your CCPA rights on your behalf, provide the
information we request to verify your identity and provide us with written confirmation that you
have given the authorized agent permission to submit the request.
4 Personal Information that we collect, use and disclose
The table below describes our Personal Information practices by reference to the categories in
the “Personal Data Collected by Eugénie Michael” section above and the categories described in
the CCPA (Cal. Civ. Code Section 1798.140(v)) and describes our practices currently and during
the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily
provide to us, such as in webforms, may contain other categories of personal information not
described below. Note that:
| CCPA statutory category | Business/commercial purpose for collection | Categories of third parties to whom we “disclose” PI for a business purpose |
Categories of third parties with whom we “share” PI |
|---|---|---|---|
|
Personal Information “PI” we collect in this category Identifiers
|
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Subprocessors (if applicable) |
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Subprocessors (if applicable) |
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Internet or network information
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Subprocessors (if applicable) |
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Sensory information
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None |
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Inferences
|
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Subprocessors (if applicable) |
5. Response Timing
5.1 We will confirm receipt of your request within ten (10) business days. If you do not receive
confirmation within the 10-day timeframe, please contact info@eugeniemichael.com
5.2 We endeavour to substantively respond to a verifiable consumer request within forty-five
(45) days of its receipt. If we require more time (up to another 45 days), we will inform you of
the reason and extension period in writing.
5.3 If you have an account with us, we will deliver our written response to that account. If you
do not have an account with us, we will deliver our written response by mail or electronically.
5.4 Any disclosures we provide will only cover the 12-month period preceding our receipt of your
request. The response we provide will also explain the reasons we cannot comply with a request,
if applicable. For data portability requests, we will select a format to provide your personal
information that is readily useable and should allow you to transmit the information from one
entity to another entity without hindrance.
5.5 We do not charge a fee to process or respond to your verifiable consumer request unless it
is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a
fee, we will tell you why we made that decision and provide you with a cost estimate before
completing your request.
Our Global Privacy Notice applies to all Colorado, Connecticut, and Virginia residents. The
following supplemental disclosures are specifically required by state law.
Colorado, Connecticut, and Virginia regulate the processing of “Personally Identifiable
Information”, which generally has the same definition as Personal Data in our global Privacy
Policy. We recognise all requests to exercise state privacy rights including both personal data
under applicable state law and Personal Data as defined in our Global Privacy Policy.
Mandatory Disclosures
The Right to Opt-Out of Marketing and Advertising
We recognise the right to opt-out of targeted marketing and advertising communications. You can
exercise this right by sending us an email at info@eugeniemichael.com. If you are a customer,
you can also opt-out of targeted marketing and advertising communications by notifying your
customer success manager.
How to Exercise Your Rights
You, or an authorised agent, may make a
request to exercise your rights to know, access, correct, delete, transfer (portability), or
opt-out of marketing by emailing us at info@eugeniemichael.com. You, or an authorized agent, can
also send your request by mail to the address listed in our Global Privacy Policy.
We reserve the right to use commercially reasonable methods to verify your identity and the
authority of any authorized agent to act on your behalf.
Time To Respond
Under state law, we have 45 days to respond to your inquiry and may add an additional 45 days
depending on the complexity of your request. Please note, however, that as a general rule we
normally respond to requests within 30 days as set forth in our Global Privacy Policy.
Right of Appeal
If we reject your request, you have the right to appeal that denial by notifying us that you
disagree with our decision by email at info@eugeniemichael.com. If you choose to appeal, please
explain why you believe you are entitled to receive the information requested despite our
denial. We will respond to any appeal within 45 days.
Right to Complain to Attorney General
If we deny any request you made under our Global Privacy Policy or this state Supplemental
Privacy Policy, you may file a complaint with your state’s attorney general.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and
managing our business to enable us to give you the best service/product and the best and most
secure experience. We make sure we consider and balance any potential impact on you (both
positive and negative) and your rights before we process your personal data for our legitimate
interests. We do not use your personal data for activities where our interests are overridden by
the impact on you (unless we have your consent or are otherwise required or permitted to by
law). You can obtain further information about how we assess our legitimate interests against
any potential impact on you in respect of specific activities by contacting us.
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.
Comply with a legal or regulatory obligation means processing your personal
data where it is necessary for compliance with a legal or regulatory obligation that we are
subject to.
THIRD PARTIES
Internal Third Parties
Other companies in the Eugénie Michael Group who provide IT and system administration services
and undertake leadership reporting.
External Third Parties
YOUR LEGAL RIGHTS
You have the right to:
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 we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data without good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we 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.
Object to processing of your personal data where we are 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 we are processing your
personal data for direct marketing purposes. In some cases, we may demonstrate that we have
compelling legitimate grounds to process your information which override your rights and
freedoms.
Request restriction of processing of your personal data. This enables you to
ask us to suspend the processing of your personal data in the following scenarios: (a) if you
want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do
not want us to erase it; (c) where you need us to hold the data even if we no longer require it
as you need it to establish, exercise or defend legal claims; or (d) you have objected to our
use of your data but we need to verify whether we have to override legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We 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 that you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are 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, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
