We take data protection very seriously and we are committed to protecting your personal information. This Privacy notice describes how we handle personal information collected through our website www.ghanima.co.uk and by any other means.

It is our policy to collect only the minimum information required from you. If you believe we have collected excessive information about you, please contact us to raise any concerns you may have.  

In this Privacy notice your personal information is sometimes called “personal data”. We collectively refer to handling, collecting, protecting or storing your personal information as ‘processing’.

Although you do not have to provide any of your personal information to us, if we ask you to do so and you refuse, we may be unable to provide you with the information, products or services you want from us.

We have appointed a Data Protection Officer (DPO) who can be contacted via the following email address: privacy@ghanima.co.uk.

Personal information is anything that enables you to be identified or identifiable, e.g., your name, job title, postal/email address and telephone number.

Collection Of Personal Information

Below are some examples of how you may provide personal information to us:

• searching and browsing our website for content
• subscribing to or ordering newsletters and/or publications
• completing forms on our website
• ordering products from us, or otherwise contacting us
• submitting CVs or work history information
• providing us with business cards or other contact information

Our website may link to third-party sites not controlled by us and which do not operate under our privacy practices. When you link to third-party sites, our privacy practices no longer apply. We encourage you to review each third-party site’s privacy policy before disclosing any personally identifiable information.

We do not intend to collect special category (also known as sensitive) personal information through our website(s) (unless we are legally required to do so). Examples of special category information are race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records. We ask that you do not provide us with special category personal information when using our website.

When you provide personal information to us, we may use it for any of the purposes described in this Privacy Policy or as stated at the point of collection (or as obvious from the context of collection), including:

• To administer and manage our website, including
• to confirm and authenticate your identity
• to personalise and enrich your browsing experience by displaying content that is more likely to be relevant and of interest to you
• to sort and analyse user data (such as determining how many users from the same organisation have subscribed to or are using the Websites);
• To understand how people, use the features and functions of our website in order to improve the user experience
• To develop our businesses and services
• To conduct quality and risk management reviews
• To monitor and enforce compliance with our Terms, including acceptable use policies; and/or
• Any other purposes for which you provided the information to us, including any of the purposes given in the ‘Collection of personal information’ section above.

We do not collect personal information for sale to third parties.

We rely on one or more of the following:

• Our legitimate interests (provided these do not interfere with your rights)
• To satisfy any legal and regulatory obligations to which we are subject
• To perform our contractual obligations to you or
• If you have agreed (consented) to us processing your personal information.

We have implemented generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, alteration or destruction.

Only authorised persons are provided access to personal information we have collected, and such individuals have agreed to maintain the confidentiality of this information.

Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by e-mail) is never completely secure.

We endeavour to protect personal information, but we cannot guarantee the security of data transmitted to or by us.

We may transfer, share or disclose the personal information we collect from you to third parties (and their respective subcontractors, and/or their subsidiaries and affiliates) for:

• the purposes for which the information has been submitted
• the purposes listed above under ‘use of your personal information’
• the administration and maintenance of our website and/or
• other internal or administrative purposes.

We also may transfer, share or disclose personal information to third party service providers of identity management, website hosting and management, data analysis, data backup, security and storage services.

We may also disclose personal information to Klarna MAS (‘Klarna’), as part of tracking sales that come from an influencer network that we are partnering with.  For more information about how Klarna will process that personal information, see Klarna’s consumer privacy notice (available here).

The third-party providers may use their own third-party subcontractors that have access to personal data (sub-processors). It is our policy to use only third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by us, and to flow those same obligations down to their sub-processors.

• We may also disclose personal information to third parties under the following circumstances:
• When explicitly requested by you
• When required to deliver products, services or information requested by you
• As otherwise set out in this Privacy Notice.

We may also disclose your personal information to law enforcement, regulatory and other government agencies and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation. This includes disclosures outside the country where you are located.

Your personal information may be transferred to and stored outside the country where you are located. Where we transfer your personal information outside the UK, we will only do so in compliance with UK data protection laws.

We will retain your personal information only for as long as we need it, given the purposes for which it was collected, or as required to do so by law. Normally, this means we will retain your personal information for 6 years.

We keep contact information (such as mailing list information) until a user unsubscribes or requests that we delete that information. If you choose to unsubscribe from a mailing list, we may keep certain limited information about you so that we may honour your request.

Where we are legally required to obtain your explicit consent to provide you with marketing materials, we will only provide you with such marketing materials if you have provided consent for us to do so.

If you opt into any subscriptions, you will receive automated emails when content is updated. If you opt into any newsletters, you will receive curated emails known as newsletters. If you select any preferences such as issues, topics, subjects or industries, you may receive email communications related to those self-selected topics.

If you want to unsubscribe from mailing lists or any subscriptions, you should look for and follow the instructions we have provided in the relevant communications to you. Alternatively, you can at any time contact us to request that such communications cease.

If you choose to unsubscribe from any or all mailings, we may retain information sufficient to identify you so that we can honour your request.

If you choose to unsubscribe from any or all mailings, we may retain information sufficient to identify you so that we can honour your request.

You have certain rights in relation to the personal information we hold about you. In particular, you have the right to:

• Request a copy of personal information we hold about you
• Ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete
• Ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information
• Object to our processing of your personal information; and/or
• Withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing)

If you would like to exercise these rights or understand if these rights apply to you, please contact us.

We have appointed a Data Protection Officer (DPO) who can be contacted via the following email address: privacy@ghanima.co.uk

If you have any questions or complaints about this Privacy notice or the way your personal information is processed by us, or would like to exercise one of your rights set out above, please contact us via the website’s contact form.

You also have the right to lodge a complaint with your local data protection regulator, which in the UK is the Information Commissioner Office (ICO). The ICO can be contacted by the following means:

Form: www.ico.org.uk/global/contact-us/email/

We may update this Privacy Notice at any time by publishing an updated version here. The new modified or amended Privacy Notice will apply from that revision date. This Privacy notice was last updated on 1st of March 2024.