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.
accordance with the terms of this policy.
1.4. In this policy, “we”, “us” and “our” refer to Oliver Cowal Consulting LTD, Oliver Cowal
Training LTD. For more information about us, see Section 17.
2. How we use your personal data
2.1. In this Section 2 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.
2.2. We may process data about your use of our website and services (“usage data”). 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
2.3. We may process your account data (“account data”). The account data may include your
name and email address. The account data may be processed for the purposes of operating
our website, providing our services, ensuring the security of our website and services,
maintaining back-ups of our databases and communicating with you. The legal basis for this
processing is our legitimate interests, namely the proper administration of our website and
2.4. We may process your information included in your personal profile on our website
(“profile data”).The profile data may include your name, address, telephone number, email
address, profile pictures, gender, date of birth, relationship status, interests and hobbies,
educational details and employment details. The profile data may be processed for the
purposes of enabling and monitoring your use of our website and services. The legal basis
for this processing is our legitimate interests, namely the proper administration of our
website and business.
2.5. 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 our legitimate interests, namely the proper administration of our website and
2.6. 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.
2.7. 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 the purpose of 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 our interest in the
proper administration of our website and business.
2.8. We may process information that you provide to us for the purpose of 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.
2.9. 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 tis processing is our legitimate interests, namely
the proper administration of our website and business and communications with users
2.10 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.
2.11 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 proception of our business against risks.
2.12 In addition to the specific purposes for which we may process your personal data set
out in this section 2. We may also process any of your personal data where such processing
is necessary for compliance with legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
2.13 Please do not supply any others persons personal data to us, unless we prompt you to
3. Providing your personal data to others
3.1. We may disclose your personal data to any member of our group of companies (this
means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as
reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2. We may disclose your personal data 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.
3.3. 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
3.4. 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 in order 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. Retaining and deleting personal data
4.1. This Section 4 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.
4.2. 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.
4.3. We will retain your personal data as follows: a) personal data category or categories will
be retained for a minimum period of 1 year following the date the data was supplied to us.
4.4. In some cases it is not possible for us to specify in advance the periods for which your
personal data will be retained. In such cases, we will determine the period of retention
based on the following criteria: a) the period of retention of personal data category will be
determined based on the options you choose in regard to email opt in
4.5. Notwithstanding the other provisions of this Section 4, we may retain your personal
data where such retention is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests of another natural
5. Security of personal data
5.1. We will take appropriate technical and organisational precautions to secure your
personal data and to prevent the loss, misuse or alteration of your personal data.
5.2. We will store all your personal data on secure servers, personal computers and mobile
devices, and in secure manual record-keeping systems.
5.3. The following personal data will be stored by us in encrypted form: contact information,
password(s) and cardholder data.
5.4. Data that is sent from your web browser to our web server, or from our web server to
your web browser, will be protected using encryption technology.
5.5. You acknowledge that the transmission of unencrypted (or inadequately encrypted)
data over the internet is inherently insecure, and we cannot guarantee the security of data
sent over the internet.
5.6. You should ensure that your password is not susceptible to being guessed, whether by a
person or a computer program. You are responsible for keeping the password you use for
accessing our website confidential and we will not ask you for your password (except when
you log in to our website).
6.1. We may update this policy from time to time by publishing a new version on our
6.2. You should check this page occasionally to ensure you are happy with any changes to
7. Your rights
7.1. You may instruct us to provide you with any personal information we hold about you;
provision of such information will be subject to:
7.2. the payment of a fee (currently fixed at GBP 10); and
7.3. the supply of appropriate evidence of your identity (for this purpose, we will usually
accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a
utility bill showing your current address).
7.4. We may withhold personal information that you request to the extent permitted by law.
7.5. You may instruct us at any time not to process your personal information for marketing
7.6. In practice, you will usually either expressly agree in advance to our use of your personal
information for marketing purposes, or we will provide you with an opportunity to opt out
of the use of your personal information for marketing purposes.
8. Third party websites
8.1. Our website includes hyperlinks to, and details of, third party websites.
8.2. We have no control over, and are not responsible for, the privacy policies and practices
of third parties.
9. Personal data of children
9.1. Our website and services are targeted at persons over the age of 18.
9.2. If we have reason to believe that we hold personal data of a person under that age in
our databases, we will delete that personal data.
10. Updating information
10.1. Please let us know if the personal information that we hold about you needs to be
corrected or updated.
11. About cookies
11.1. 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.
11.2. 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.
11.3. 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.
12. Cookies that we use
you navigate our website (cookies used for this purpose are: identify cookies);
(cookies used for this purpose are: identify cookies);
navigate our website (cookies used for this purpose are: identify cookies);
to personalise our website for you (cookies used for this purpose are: identify
user accounts, including preventing fraudulent use of login credentials, and to
protect our website and services generally (cookies used for this purpose are:
relevant to you (cookies used for this purpose are: identify cookies);
website and services (cookies used for this purpose are: identify cookies); and
cookies more generally (cookies used for this purpose are: identify cookies).
13. Cookies used by our service providers
when you visit our website.
13.2. 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
available at: https://www.google.com/policies/privacy/. The relevant cookies are: identify
13.3. We may publish Google AdSense interest-based advertisements on our website. These
are tailored by Google to reflect your interests. To determine your interests, Google will
track your behaviour on our website and on other websites across the web using cookies.
You can view, delete or add interest categories associated with your browser by visiting:
https://adssettings.google.com. You can also opt out of the AdSense partner network cookie
using those settings or using the Network Advertising Initiative’s multi-cookie optout
mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms
be maintained. To ensure that an opt-out is maintained in respect of a particular browser,
you may wish to consider using the Google browser plug-ins available at:
https://support.google.com/ads/answer/7395996. The relevant cookies are: identify
14. Managing cookies
14.1. 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);
c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
deletemanage-cookies (Internet Explorer);
e) https://support.apple.com/kb/PH21411 (Safari); and Privacy and cookies policy:
14.2. Blocking all cookies will have a negative impact upon the usability of many websites.
14.3. If you block cookies, you will not be able to use all the features on our website.
15. Cookie preferences
16. Our details
16.1. This website is owned and operated by Oliver Cowal Consulting LTD
16.2. We are registered in Scotland under registration number SC563607 , and our
registered office is at 14 Cowal Crescent, Kirkintilloch, Glasgow, G66 3SZ
16.3. You can contact us:
a) by post, to the postal address given above;
b) using our website contact form;
c) by telephone, on the contact number published on our website from time to time;
d) by email, using the email address published on our website from time to time.
17. Data protection officer
17.1. Our data protection officer’s contact details are:
a) Data Protection Officer, Mark Oliver, Oliver Cowal Consulting LTD, 14 Cowal Crescent
Kikintilloch Glasgow G66 3SZ