EU GDPR PRIVACY POLICY
MIRIAM SIMON GROWTH STRATEGY
INTRODUCTION
Miriam Simon Growth Strategy is committed to protecting and respecting your privacy. We wish to be transparent regarding how we process your personal information and demonstrate that we are accountable, in accordance with the EU General Data Protection Regulation (EU 2016/679). It is the intention of this Privacy Policy to explain to you our privacy management practices in relation to the personal information that we collect and process about you. In accordance with the EU GDPR (2016/679) and the Data Protection Act 2018, Miriam Simon Growth Strategy is identified as a Data Controller, there may be occasions when we are also identified as a Data Processor. This online Privacy Policy relates to personal information which we collect through the website www.miriamsimon.ie and associated technologies, including personal information, which is collected electronically, including email communication. This Privacy Policy does not relate to personal information which is collected and processed manually. By willingly providing personal and other information, you consent to the terms and conditions of this Privacy Policy. Please read this policy carefully, as this document sets out the basis on how we collect and process the personal information you provide to us.
WHO WE ARE ?
Miriam Simon Growth Strategy is a successful Irish based Strategy Business, (VAT No: IE 8955090B). With over thirty years retail experience, our Founder, Miriam Simon, has a passion for retail and a proven track record of real success. Over many years, we have developed a range of strategies aimed at maximising commercial success for Businesses and the Retail Sector.
HOW WE COLLECT PERSONAL INFORMATION ABOUT YOU
When you browse the website www.miriamsimon.ie we may ask for personal information, such as your name and email address. We may also collect information about you when you are on the internet such as the website you came from, IP address, domain types, i.e., co.uk and .com, your browser type, the country where your internet service is located, the pages of our site that were viewed during your visit and search terms you used. This information is only used for our own research and to improve our services to you. In addition, your IP address is used to gather local broad demographic information. To measure the effectiveness of our online presence, www.miriamsimon.ie may use cookies to determine the path users take on the site and to identify repeat visitors to the website. Personal information is collected when you register on www.miriamsimon.ie either by email or when you complete and submit any of our online forms. The categories of personal information that we collect and process include your name, company name, email address, contact phone number, and date of birth.
HOW WE USE YOUR PERSONAL INFORMATION
Miriam Simon Growth Strategy is legally mandated to identify the specific lawful bases which allow us to collect and process your personal information. In accordance with EU GDPR legislation, we rely on the following legal bases. Consent, Contractual Necessity, Legal Obligation, Legitimate Interest, Public Interest. There may be occasions when it is necessary to engage with third-party stakeholders and working partners for the following purposes: To facilitate the delivery of our services, to provide the services on our behalf, to perform related services or to assist us in analysing how our services are used. We may process your personal information for more than one lawful basis, depending on the specific purpose for which we are using your personal information. The following table illustrates the various purposes for which your personal information may be collected and processed, and the legal bases for processing that personal information. Please note, however, that this is not an exhaustive list of our data processing functions.
SOURCE OF COLLECTION
You provide personal information when you visit www.miriamsimon.ie. Personal information is also collected when you send an email and when you complete and submit any of our online forms. We use the social media platforms of Facebook, LinkedIn, Instagram, and Twitter. Personal information may be collected through these identified social media platforms.
COOKIES
Cookies are used on www.miriamsimon.ie. Cookies are files with a small amount of data that is commonly used as an anonymous, unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive. The website www.miriamsimon.ie uses cookies which are necessary to enable core functionality, such as security, network management and accessibility. Google Analytics is used to collect information and to improve the services offered and provided. You have the option to either accept or refuse these cookies, and know when a cookie is being sent to your computer. If you choose to refuse cookies, you may not be able to use some portions of the service. For full information on the use of Cookies, we would refer you to our separate Cookie Policy, which you will find on www.miriamsimon.ie
THIRD PARTY SITES
There may be occasions when www.miriamsimon.ie contains links to other sites. If you click on a third-party link, you will be directed to that site. Please be aware that these third-party sites are not operated by Miriam Simon Growth Strategy, we strongly advise that you review the privacy policies of any third-party sites. We do not take any responsibility for the content of privacy policies or practices of any third-party sites or services.
INTERNATIONAL TRANSFERS
We do not actively transfer personal information beyond European territories. However, personal information entered onto www.miriamsimon.ie may be transferred to a server in the United States of America and stored there. Please note that outside the EU and the EEA, different standards of data protection might apply. By completing and submitting any online forms on our website, you acknowledge and consent that data may be transferred across international borders, including to countries outside the EU and the EEA. Miriam Simon Growth Strategy will ensure that when personal information is transferred outside the EU and the EEA that local data protection standards meet EU GDPR requirements.
SECURITY OF PERSONAL INFORMATION
Miriam Simon Growth Strategy is committed to the protection and security of your personal information. A variety of security technologies and procedures are used to protect your personal information from unauthorised use and access, accidental loss, unlawful destruction, alteration, and unlawful disclosure. As effective as security practices are, no physical or electronic system is entirely secure. We cannot guarantee the complete security of databases, nor can we guarantee that information that you supply will not be intercepted while being transmitted over the internet. Strict security controls have been implemented to ensure that your privacy is safeguarded at every level. We will continue to revise policies and procedures and review systems, and we will implement additional security features as new technologies become available. Any transmission of personal information is at your own risk. When we receive your personal information, we use appropriate security measures to prevent your personal information from being compromised in any way. When you contact Miriam Simon Growth Strategy to ask about your personal information, we may ask you to identify yourself. This is to help protect your personal information.
RETENTION OF PERSONAL INFORMATION
Personal information is not retained for longer than is considered necessary to enable Miriam Simon Growth Strategy to provide our services to our clients. Independent Statutory Legislation and Regulatory Obligations will influence the retention period of various categories of personal information that is collected and further processed. Further information regarding the retention of personal information is detailed in our separate EU GDPR Retention Policy, a copy of which is available upon request.
CHILDREN
It is not the practice of Miriam Simon Growth Strategy to gather and process the personal information pertaining to children under the age of 16 years. If you are under 16, do not access, use, or provide personal information on www.miriamsimon.ie or through any of its features. If we learn that we have collected or received personal information from a child under 16 without parental consent, we will delete that information.
EMAIL MARKETING
We may process your personal information to contact you regarding our marketing or promotional offers, such as our newsletters and other information that we consider might be of interest to you. You may opt out of receiving any or all of these communications from Miriam Simon Growth Strategy by following the unsubscribe link or instructions provided in any email we send to you.
YOUR PERSONAL INFORMATION?
There may be circumstances when Miriam Simon Growth Strategy is legally mandated to share personal information in accordance with Independent Statutory legislation and regulatory requirements. In addition, there may be circumstances where it is necessary to share personal information with our Working Partners and Stakeholders to enable us to provide and deliver our products and services efficiently. Miriam Simon Growth Strategy will ensure that all Data Sharing Agreements and Contracts have been implemented prior to the sharing of any personal information. Access to personal information to external Stakeholders and Working Partners will only be afforded when a specific legal and lawful purpose(s) has been identified. Detailed below is a list of Stakeholders and Working Partners with whom personal information may be shared for the purposes of providing our services to our clients. This list is, however, not exhaustive: IT Provider/Support Web Hosting Co Business Partners/External Stakeholders Mailchimp Stripe
DATA SUBJECT RIGHTS
In accordance with the EU General Data Protection Regulation (EU 2016/679) and the Data Protection Act (2018), you are afforded the following rights in certain circumstances. Right of Access: You have the right to obtain confirmation whether personal information is collected and processed about you and, where that is the case, access to the personal data, including the purposes of processing and the categories of personal data concerned. The recipients or categories of recipients to whom the personal information has been or will be disclosed. You may also submit a written request for a copy of personal information you believe is being processed about you. Right to Rectification: You have the right to the rectification of inaccurate personal information about you without undue delay. Right to Erasure: You may request Miriam Simon Growth Strategy to delete your personal information; however, this is not an absolute right, and any such request will be considered in accordance with EU GDPR legislation and local legislation. Right to Restrict & Object: You have the right to restrict and object to Miriam Simon Growth Strategy using your personal information. Right to Data Portability: Upon receipt of your written request, where possible, a digital copy of your personal information can be shared with you or another organisation.
HOW TO CONTACT US
Taking into consideration the size and data processing activities of our business, Miriam Simon Growth Strategy is not legally mandated to appoint a designated Data Protection Officer. However, in the event you may have concerns regarding how we collect and process your personal information, you can send us an email to: miriam@miriamsimon.ie
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CHANGES TO THIS PRIVACY POLICY
This Privacy Policy will be updated from time to time, particularly to reflect any changes made regarding how we collect and process your personal information. Details of any changes made will be posted here. By continuing to use www.miriamsimon.ie after any changes are posted, you accept and agree to this privacy policy.
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AI POLICY
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PURPOSE AND SCOPE
This policy outlines clear guidelines for the ethical and responsible use of AI within Miriam Simon Growth Strategy. It applies to all employees, contractors, and partners who interact with AI technologies for business purposes. The aim is to demonstrate our commitment to leveraging AI in alignment with our core values while fostering trust among employees and customers. By offering practical directives, this policy helps sets out how we use AI tools effectively, ensuring compliance with regulations and enabling controlled innovation.
DATA PRIVACY AND ETHICS
Protecting our data and ensuring ethical AI practices are central to this policy. All AI usage must comply with regulations such as GDPR and the EU AI Act, safeguarding individuals’ rights while minimising risks.
We commit to legal and ethical AI usage, respecting the limitations of these technologies by:
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Data Privacy: We ensure all our staff receive training and understand how data is used by the models and what kind of data is safe for sharing and where personal or proprietary data needs to be anonymised before use.
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Bias Prevention: AI reflects the data it is trained upon, and we recognise the risk of perpetuating societal biases. At Miriam Simon Growth Strategy, we are dedicated to producing AI-generated content that is inclusive and ethical. We customise our settings wherever possible to require diverse perspectives in our answers, and we take active steps to identify and mitigate any biases, ensuring our content is accessible and fair to all.
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Transparency: At Miriam Simon Growth Strategy, we are committed to transparency about our AI usage. This is in accordance with Article 52 of the EU AI Act. We communicate our use of AI on our website. And our commitment to transparency is fundamental to our approach to ethical use.
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Human Oversight: AI is a complementary tool, enhancing, not replacing, human ingenuity and judgement. All our AI-generated content goes through human review before being used anywhere in our material. This ensures quality and alignment with our educational standards.
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Responsible Use: All staff are required to adhere to the set of approved AI tools. We ensure that all staff are familiar with this policy, which is continuously reviewed and updated to ensure adherence to regulations. The current set of AI tools we utilise is as follows:
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ChatGPT
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Perplexity Claude
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Gemini
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Whispr
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These tools have been evaluated for their security, privacy, and compliance with GDPR and are deemed suitable for use in our educational activities. As advancements are made and new tools emerge, we will update this list to reflect the most effective and secure options for our courses.