1. Introduction
At Paseda360 (part of the Ask Why Limited Group) we take privacy and the security of your personal data seriously. We are committed to respecting your privacy rights and to handle your data fairly and legally at all times.

This policy sets out what we do with your data and what we do to keep it secure. It also explains where and how we collect your personal data, as well as your rights over any personal data we hold about you.

This policy applies to you if you provide data through our websites Paseda360.com, over the phone, email, post, text or interacting with us face to face or on social media (i.e., via our “Services”).

Who we are
When we say ‘we’ or ‘us’ in this policy, we are referring to Paseda360, Suite 53, Basepoint, Chichester Enterprise Centre, Terminus Rd, Chichester PO19 8FY / office@paseda360.com.

2. What data we collect about you
We may process certain types of personal data about you as follows:

• Identity and Contact Information that you provide to us such as your name, email address and telephone numbers
• Submission Information relating to the content of your form submission, for example specifics of your product or service enquiry, request for information, subscription to our newsletter, and brochure and guide downloads
• Transaction and Financial Information for the purpose of processing your purchase including date of birth, invoice address, delivery address, bank account and payment card details
• Transaction Information about the product and services that we provide to you (including payment transaction information for example, what we have provided to you, when, what you paid and how)
• Communication Information – your contact details and details of the emails and other electronic communications you receive from us, including open and link click data
• Communication Information – a record of communications with you including by email, phone, text or post
• Marketing and communication preferences
• Interests, feedback or survey response you give to us, including by email, phone, text, post, when you interact with us face to face or via social media
• Information about any device you have used to access our Services (e.g., your device’s make and model, browser, IP address, location) and also how you use our Services

3. How we collect your data
Your data may be collected through online forms on our website’s (paseda360.com and learn.paseda360.com), over the phone, email, post, text or interacting with us face to face or on social media (via our “Services”).

We may also collect data in the following ways:

Cookies
We may use cookies on our website’s (paseda360.com and learn.paseda360.com) to ensure the integrity of the submission process, to personalise the specific Site and compile aggregated statistics about usage of our Site.

A cookie is a piece of information that is stored on your computer’s hard drive by your web browser. Most browsers accept cookies automatically, but usually you can alter the settings of your browser to prevent automatic acceptance. If you reject the use of cookies, please note that the efficient operation of the website that you are using may be affected.

Google Analytics
We use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns when they interact with our website’s (paseda360.com and learn.paseda360.com). This is to understand the number of visitors to various parts of the Site and how our Site is used. This information is processed without identifying the user.

We may also collect data through:

• Advertising networks such as Facebook and YouTube
• Technical, payment and delivery services

Marketing communications and data collection
As part of the online submission process to receive our newsletter, request information (including brochure and guide downloads) or to purchase product and services we collect personal data. This is so that we can respond to your enquiries, provide useful and relevant information, news and material of interest as well as latest product and service information and promotional offers.

We use third party providers, such as Mailchimp, JotForm Stripe payments and Direct Pay, to collect, store and use your data to deliver automated email campaigns including our newsletter and other email communications to people subscribed to our mailing lists.
We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our newsletter and communications.
You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of our marketing emails or by emailing us at Office@paseda360.com

4. How we use your data
We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the contract between us
• Where it is necessary for our legitimate interests
• Where we need to comply with a legal or regulatory obligation Paseda360 legitimate interests
• The normal legal basis for processing customer data is that it is necessary for the legitimate interests of Paseda360.

The data we collect may be used to:

• Process customer contacts, enquiries, requests for products, services and information, complaints or disputes
• Sell and supply products and services to our customers
• Process financial transactions
• Promote, market and advertise our products and services
• Measure and understand the effectiveness of our marketing and advertising
• Send communications including promotional offers which may be of interest to you
• Deliver electronic marketing (with your agreement)
• Understand our customers’ behaviour, activities, preferences, and needs
• Improve existing products and services and develop new products and services
• Improve customer relations, experiences and service interactions including your website experience
• Administer Paseda360 and our websites
• Conduct market research
• Provide feedback, a review or a testimonial for use in marketing or improving our products and services
• Enable you to partake in a prize draw, competition or survey
• Internal record keeping
• Satisfy any legal, regulatory, accounting, or reporting requirements
• Fulfil our duties to our customers, colleagues, suppliers and other stakeholders.
• Provide for the safety and security of our customers, colleagues, and other individuals.

In general, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email, phone, text and post. You can withdraw consent to marketing at any time by emailing us at

5. How long we keep your data
We will only retain your data for as long as necessary to fulfil the purposes set out in this policy, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

6. Third Parties
We will only disclose personal information about you to third parties for processing purposes associated with the supply of products and services, including service providers (e.g., I.T, Marketing), professional advisers (e.g., legal, accounting, financial), statutory and regulatory (e.g., HMRC) or elsewhere when you have consented to such disclosures, or where such disclosures are required or permitted by law.
We will never sell or rent your personal data to other organisations for marketing purposes.

7. Links to Third Party Sites
Our websites may provide links to other websites, which Paseda360 has no control over. These websites, and others linked to from this Policy, are owned and operated by a third party and they are responsible for processing personal data in accordance with their own privacy policies.

8. International transfers
To deliver products and services to you, it is sometimes necessary for Paseda360 to share your data with providers outside of the UK. We will seek to ensure that the transfer will be compliant with data protection law and all personal data will be secure. If deemed necessary we will seek your specific consent to transfer.

9. Security of your personal data
We use administrative, technical, and physical measures to safeguard personal data against loss, theft and unauthorised uses, access or modifications. We limit access to your personal data to those colleagues, agents, contractors and other third parties who have a business need to know.

10. Accessing your personal data and your legal rights
You have the right to access, amend and delete personal information that we hold about you by contacting us using the details below. You also have the right to:
ask what personal data we hold about you, subject to a fee specified by law
to opt-out of any marketing communications that we may send you

Contacting us
If you have any questions about your personal data or no longer wish to receive communications from Paseda360 you can email us at Office@paseda360.com
or by clicking the ‘update subscription preferences’ link at the base of our marketing email communications.

You have the right to lodge a complaint with the Information Commissioner’s Office. Further information is available at https://ico.org.uk

11. Changes to our Privacy Policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.

Your continued use of our Services or our websites following the posting of changes means that you consent to those changes.
This version of this Privacy Policy is effective as of 5th December 2022.