Felicia Komornyik Virtual Assistant customer privacy notice
This privacy notice tells you what to expect us to do with your personal information.
- Contact details
- What information we collect, use, and why
- Lawful bases and data protection rights
- Where we get personal information from
- How long we keep information
- Who we share information with
- How to complain
Contact details
Felicia Kasalyak-Komornyik
Email: [email protected]
What information we collect, use, and why
We collect or use the following information to provide services and goods, including delivery:
- Names and contact details
- Addresses
- Purchase or account history
- Payment details (including card or bank information for transfers and direct debits)
- Account information
We collect or use the following information for the operation of customer accounts and guarantees:
- Names and contact details
- Addresses
- Payment details (including card or bank information for transfers and direct debits)
- Purchase history
- Account information, including registration details
- Information used for security purposes
- Marketing preferences
We collect or use the following information to prevent, detect, investigate or prosecute crimes:
- Names and contact information
- Customer or client accounts and records
- Financial transaction information
We collect or use the following information for service updates or marketing purposes:
- Names and contact details
- Addresses
- Marketing preferences
- Location data
- Purchase or viewing history
- Website and app user journey information
We collect or use the following information to comply with legal requirements:
- Name
- Contact information
- Any other personal information required to comply with legal obligations
We collect or use the following personal information for dealing with queries, complaints or claims:
- Names and contact details
- Address
- Payment details
- Account information
- Purchase or service history
- Relevant information from previous investigations
- Customer or client accounts and records
- Financial transaction information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
- Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
- Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
- Your right to erasure – You have the right to ask us to delete your personal information. Read more about the right to erasure.
- Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
- Your right to object to processing – You have the right to object to the processing of your personal data. Read more about the right to object to processing.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
- Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide services and goods are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information to prevent, detect, investigate or prosecute crimes are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for legal requirements are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
- Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
- Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
- Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
- Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
- Directly from you
How long we keep information
For more information on how long we store your personal information or the criteria we use to determine this please contact us using the details provided above.
We apply the following timeframes to the data we hold:
- Client Contracts & Agreements: Retained for 6 years after the termination of the contract. This is to ensure compliance with the statute of limitations for potential legal or contractual claims.
- Financial & Tax Records: Retained for 6 years from the end of the last company financial year, in accordance with HMRC requirements.
- Operational Project Files & Correspondence: Retained for 2 years after the completion of a project or contract, unless a specific request for earlier deletion is made by the client.
- Access Credentials (LastPass): Access to client passwords and systems is revoked and credentials are deleted immediately (within 24 hours) upon the termination of the service agreement.
- Prospective Client Data (Leads): Contact details for inquiries that do not result in a contract are deleted after 12 months.
Once the retention period has expired, data will be permanently destroyed:
- Digital Files: Permanently deleted from cloud storage (Google Drive/Dropbox) and local drives, including emptying “trash” or “recycle” bins.
- LastPass: Vault entries and shared folders are permanently deleted or access is formally revoked.
- Physical Records: Any paper documents containing personal data will be cross-cut shredded.
Who we share information with
Data processors
Google Workspace: This data processor does the following activities for us: Provides email hosting, document storage (for contracts and project files), and calendar management.
LastPass: This data processor does the following activities for us: Securely stores and encrypts client login credentials using zero-knowledge architecture to allow for safe access to client systems.
FreeAgent: Stores financial data, client names, and billing addresses for tax reporting and bookkeeping.
Others we share personal information with
- Insurance companies
- Professional or legal advisors
- Financial or fraud investigation authorities
- Relevant regulatory authorities
- Organisations we’re legally obliged to share personal information with
- Publicly on our website, social media or other marketing and information media
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113