Privacy Policy - Tsma

Privacy Policy (Updated October 4th, 2021)

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of

our website visitors and service users; in other words, where we determine the purposes and

means of the processing of that personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the

provision of our website and services, we will ask you to consent to our use of cookies when you

first visit our website.

1.4 In this policy, “we”, “us” and “our” refer to Next Curve Network Ltd which also operates as The

Sales Managers’ Academy®.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) the purposes for which we may process personal data; and

(c) the legal bases of the processing.

3.2 The usage data may include your IP address, geographical location, browser type and version,

operating system, referral source, length of visit, page views and website navigation paths, as

well as information about the timing, frequency and pattern of your service use. The source of

the usage data is our analytics tracking system. This usage data may be processed for the

purposes of analysing the use of the website and services]. The legal basis for this processing is

our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process your personal data that are provided during the use of our services (“service

data”). The service data may include your name, email and phone number and other contact

information. The source of the service data is you or your employer. The service data may be

processed for the purposes of operating our website, providing our services, and communicating

with you. The legal basis for this processing is our legitimate interests, namely the proper

administration of our website and business or the performance of a contract between you and us

and/or taking steps, at your request, to enter into such a contract.

3.4 We may process information contained in any enquiry you submit to us regarding goods and/or

services (“enquiry data”). The enquiry data may be processed for the purposes of offering,

marketing and selling relevant goods and/or services to you. The legal basis for this processing is

consent.

3.5 We may process information that you provide to us for subscribing to our email notifications

and/or newsletters (“notification data”). The notification data may be processed for the purposes

of sending you the relevant notifications and/or newsletters. The legal basis for this processing is

consent.


3.6 We may process information that you post for publication on our

website or through our services ("publication data"). The publication data may be processed

for the purposes of enabling such publication and administering our website and services. The

legal basis for this processing is consent OR our legitimate interests, namely the proper

administration of our website and business OR the performance of a contract between you and

us and/or taking steps, at your request, to enter into such a contract.

3.7 We may process information relating to our customer relationships, including customer contact

information ("customer relationship data"). The customer relationship data may include your

name, your employer, your job title or role, your contact details, and information contained in

communications between us and you or your employer. The source of the customer relationship

data is you or your employer. The customer relationship data may be processed for the purposes

of managing our relationships with customers, communicating with customers, keeping records

of those communications and promoting our products and services to customers. The legal basis

for this processing is consent OR our legitimate interests, namely the proper management of our

customer relationships.

3.9 We may process information relating to transactions, including purchases of goods and services,

that you enter into with us and/or through our website ("transaction data"). The transaction

data may include your contact details, your card details and the transaction details.] The

transaction data may be processed for supplying the purchased goods and services and keeping

proper records of those transactions. The legal basis for this processing is the performance of a

contract between you and us and/or taking steps, at your request, to enter into such a contract

and our legitimate interests, namely the proper administration of our website and business.

3.10 We may process information contained in or relating to any communication that you send to us

("correspondence data"). The correspondence data may include the communication content

and metadata associated with the communication. Our website will generate the metadata

associated with communications made using the website contact forms. The correspondence data

may be processed for the purposes of communicating with you and record-keeping. The legal

basis for this processing is our legitimate interests, namely the proper administration of our

website and business and communications with users.

3.12 We may process any of your personal data identified in this policy where necessary for the

establishment, exercise or defence of legal claims, whether in court proceedings or in an

administrative or out-of-court procedure. The legal basis for this processing is our legitimate

interests, namely the protection and assertion of our legal rights, your legal rights and the legal

rights of others.

3.14 We may process any of your personal data identified in this policy where necessary for the

purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining

professional advice. The legal basis for this processing is our legitimate interests, namely the

proper protection of our business against risks.

3.15 In addition to the specific purposes for which we may process your personal data set out in this

Section 3, we may also process [any of your personal data] where such processing is necessary

for compliance with a legal obligation to which we are subject, or to protect your vital interests or

the vital interests of another natural person.

3.16 Please do not supply any other person's personal data to us, unless we prompt you to do so.


4. Providing your personal data to others

4.1 We may disclose your personal data identified in this policy to our insurers and/or professional

advisers] insofar as reasonably necessary for the purposes of obtaining or maintaining insurance

coverage, managing risks, obtaining professional advice, or the establishment, exercise or

defence of legal claims, whether in court proceedings or in an administrative or out-of-court

procedure.

4.3 We may disclose your personal data identified in this policy to core team members or

subcontractors identified at www.nextcurve.team/meetheteam/ and other associates insofar as

reasonably necessary for the performance of a contract between you and us and/or taking steps,

at your request, to enter into such a contract

4.4 Financial transactions relating to our website and services may be handled by our payment

services providers, as and when they are appointed. We will share transaction data with our

payment services providers only to the extent necessary for the purposes of processing your

payments, refunding such payments and dealing with complaints and queries relating to such

payments and refunds. You can find information about the payment services providers' privacy

policies and practices at [URLs].

4.5 We may disclose your enquiry data to one or more of those selected third-party suppliers of

goods and services identified on our website for the purpose of enabling them to contact you so

that they can offer, market and sell to you relevant goods and/or services. Each such third party

will act as a data controller in relation to the enquiry data that we supply to it; and upon

contacting you, each such third party will supply to you a copy of its own privacy policy, which

will govern that third party's use of your personal data.

4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose

your personal data where such disclosure is necessary for compliance with a legal obligation to

which we are subject, or to protect your vital interests or the vital interests of another natural

person. We may also disclose your personal data where such disclosure is necessary for the

establishment, exercise or defence of legal claims, whether in court proceedings or in an

administrative or out-of-court procedure.

4.7 You acknowledge that personal data that you submit for publication through our website or

services] may be available, via the internet, around the world. We cannot prevent the use (or

misuse) of such personal data by others.

5. Retaining and deleting personal data

5.1 This Section 6 sets out our data retention policies and procedure, which are designed to help

ensure that we comply with our legal obligations in relation to the retention and deletion of

personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is

necessary for that purpose or those purposes.

5.3 Notwithstanding the other provisions of this Section 6, we may retain your personal data where

such retention is necessary for compliance with a legal obligation to which we are subject, or to

protect your vital interests or the vital interests of another natural person.


6. Amendments

6.1 We may update this policy from time to time by publishing a new version on our website.

6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

6.3 We may notify you of significant changes to this policy by email.

7. Your rights

7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some

of the rights are complex, and not all the details have been included in our summaries.

Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a

full explanation of these rights.

7.2 Your principal rights under data protection law are:

(a) the right to access; (b) the right to rectification; (c) the right to erasure; (d) the right to

restrict processing; (e) the right to object to processing; (f) the right to data portability; (g) the

right to complain to a supervisory authority; and (h) the right to withdraw consent.

7.3 You have the right to confirmation as to whether we process your personal data and, where we

do, access to the personal data, together with certain additional information. That additional

information includes details of the purposes of the processing, the categories of personal data

concerned and the recipients of the personal data. Providing the rights and freedoms of others

are not affected, we will supply to you a copy of your personal data. The first copy will be

provided free of charge, but additional copies may be subject to a reasonable fee. You can access

your personal data by emailing hello@nextcurve.team

7.4 You have the right to have any inaccurate personal data about you rectified and, considering the

purposes of the processing, to have any incomplete personal data about you completed.

7.5 In some circumstances you have the right to the erasure of your personal data without undue

delay. Those circumstances include: [the personal data are no longer necessary in relation to the

purposes for which they were collected or otherwise processed; you withdraw consent to

consent-based processing; you object to the processing under certain rules of applicable data

protection law; the processing is for direct marketing purposes; and the personal data have been

unlawfully processed]. However, there are exclusions of the right to erasure. The general

exclusions include where processing is necessary: [for exercising the right of freedom of

expression and information; for compliance with a legal obligation; or for the establishment,

exercise or defence of legal claims].

7.6 In some circumstances you have the right to restrict the processing of your personal data. Those

circumstances are: you contest the accuracy of the personal data; processing is unlawful, but

you oppose erasure; we no longer need the personal data for the purposes of our processing, but

you require personal data for the establishment, exercise or defence of legal claims; and you

have objected to processing, pending the verification of that objection. Where processing has

been restricted on this basis, we may continue to store your personal data. However, we will only

otherwise process it: with your consent; for the establishment, exercise or defence of legal

claims; for the protection of the rights of another natural or legal person; or for reasons of

important public interest.


7.7 You have the right to object to our processing of your personal data on

grounds relating to your situation, but only to the extent that the legal basis for the processing is

that the processing is necessary for: the performance of a task carried out in the public interest

or in the exercise of any official authority vested in us; or the purposes of the legitimate interests

pursued by us or by a third party. If you make such an objection, we will cease to process the

personal information unless we can demonstrate compelling legitimate grounds for the

processing which override your interests, rights and freedoms, or the processing is for the

establishment, exercise or defence of legal claims.

7.8 You have the right to object to our processing of your personal data for direct marketing

purposes (including profiling for direct marketing purposes). If you make such an objection, we

will cease to process your personal data for this purpose.

7.9 You have the right to object to our processing of your personal data for scientific or historical

research purposes or statistical purposes on grounds relating to your situation, unless the

processing is necessary for the performance of a task carried out for reasons of public interest.

7.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party

or to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your

personal data from us in a structured, commonly used and machine-readable format. However,

this right does not apply where it would adversely affect the rights and freedoms of others.

7.11 If you consider that our processing of your personal information infringes data protection laws,

you have a legal right to lodge a complaint with a supervisory authority responsible for data

protection. You may do so in the EU member state of your habitual residence, your place of work

or the place of the alleged infringement.

7.12 To the extent that the legal basis for our processing of your personal information is consent, you

have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of

processing before the withdrawal.

7.13 You may exercise any of your rights in relation to your personal data by written notice to us.

8. About cookies

8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web

server to a web browser and is stored by the browser. The identifier is then sent back to the

server each time the browser requests a page from the server.

8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be

stored by a web browser and will remain valid until its set expiry date, unless deleted by the user

before the expiry date; a session cookie, on the other hand, will expire at the end of the user

session, when the web browser is closed.

8.3 Cookies do not typically contain any information that personally identifies a user, but personal

information that we store about you may be linked to the information stored in and obtained

from cookies.


9. Cookies that we use

9.1 We use cookies for the following purposes: (a) authentication – we use cookies to identify you

when you visit our website and as you navigate our website (cookies used for this purpose are:

identify cookies; (b) status – we use cookies to help us to determine if you are logged into our

website (cookies used for this purpose are: identify cookies); (c) security – we use cookies as an

element of the security measures used to protect user accounts, including preventing fraudulent

use of login credentials, and to protect our website and services generally (cookies used for this

purpose are: identify cookies); (d) analysis – we use cookies to help us to analyse the use and

performance of our website and services (cookies used for this purpose are: identify cookies);

and (g) cookie consent – we use cookies [to store your preferences in relation to the use of

cookies more generally (cookies used for this purpose are: identify cookies).

10. Cookies used by our service providers

10.1 Our service providers use cookies and those cookies may be stored on your computer when you

visit our website.

10.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information

about website use by means of cookies. The information gathered relating to our website is used

to create reports about the use of our website. Google's privacy policy is available at:

https://www.google.com/policies/privacy/.

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for


doing so vary from browser to browser, and from version to version. You can however obtain up-

to-date information about blocking and deleting cookies via these links:


(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

(Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);


(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-

manage-cookies (Internet Explorer);


(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on our website.

12. Our details

12.1 Our website is owned and operated by Next Curve Network Ltd

12.2 We are registered in England and Wales under registration number 04609132, and our registered

office is at Tax Assist Accountants, 16 Blatchington Road, Hove, East Sussex, BN3 3YN

12.3 Our principal place of business is at 1 School Rd, Upper Beeding, Steyning, BN44 3HY


12.4 You can contact us:

(a) by post, to the postal address given above; (b) using our website contact

form; (c) by telephone, on +44 (0) 7771 592470 (d) by email, using the

email address hello@nextcurve.team

12.5 Our data protection officer is David Mason. His contact details are:

david.mason@nextcurve.team, Tel +44 (0) 7771 592470.

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