Supreme PA

Diana Group Privacy Policy

 

Effective Date 25 May 2018

Introduction

Diana Group, trading under the brands: Nanny & Butler, Sigillus and SupremePA (“us”, “our”, and “we”) takes your privacy seriously. This Privacy Policy has been designed to answer your questions about your privacy rights while you engage our websites and mobile application(s) (collectively, “Sites”). If you need more information, please refer to the Contact Us Section of this policy below.

Purpose

This Privacy Policy applies to Diana Group Sites that link to or reference this Policy. This Policy describes how we handle Personal Information, as defined in the section below, and the choices available to you regarding: i) how we collect, use, and access your Personal Information; and ii) how to confirm your Personal Information is updated, corrected, and/or deleted. Additional terms and information about Diana Group’s Personal Information handling practices may be provided in offer descriptions, supplement statements or contract terms, or notices provided prior to or at the time of information collection.

Definition of Personal Information

“Personal information” is any information that can be used to identify an individual, and may include, but is not limited to, for example, name, address, email address, phone number, login information (account number, password), marketing preferences, social media account information, IP addresses, location data (if combined with other identifiers), personal identification numbers (passport numbers, social security numbers, etc.), photos, video footage with your likeness, audio recordings, payment card number, criminal record, educational and professional records, and any form of biometric, health, genetic, racial, religion, political affiliation, gender-based, sexual preference, age-related, or other identifying personal data. If we link other data with your personal information, we will treat that linked data as Personal Information. We also collect Personal Information from trusted third-party sources and engage third parties to collect Personal Information to assist us.

Collection and Use of Your Personal Information

We may collect a variety of information, including Personal Information, about you as you use our Sites and interact with us. A summary of what we collect and how we use the Personal Information associated with our main Site is compiled for your convenience below.

Client /Member/Candidate Profile:
When you become a Diana Group client or member or candidate, we collect information about you including (but not limited to) your name, your employer’s name, your work address (including your country location), and your email address. We may also collect your personal email address, a personal mailing address, and a mobile phone number. We ask members to voluntarily provide additional information, such as information about their educational background, professional experience, a photo, social media identifiers, and some other information. We process your personal information to deliver benefits to you, and to inform you of Diana Group related events, content, and other opportunities associated. We may also use this information to help us understand your needs and interests to better tailor our Site to meet your needs.

Personal Information Provided to Process Payment

You may purchase Solutions using a payment card. Payment card information may be provided directly by users, via an Diana Group Site or authorised third party event registration vendor site, into the PCI/DSS-compliant payment processing service to which Diana Group subscribes. We do not process or store the card information. Occasionally, members or customers ask Diana Group employees or Diana Group event volunteers to enter payment card or other financial account information into the PCI/DSS-compliant payment processing service to which Diana Group subscribes. We strongly encourage you not to submit this information by email. When Diana Group employees receive payment card or other financial account information from customers or members by email, fax, phone, or mail, it is entered as instructed and then deleted or destroyed unless specifically asked by our members at Sigillus Lifestyle in order to process payments on their behalf.

Personal Information Collected Electronically

Personal Information Collected on Sites

We use automatic data collection tools on our Sites, such as cookies, embedded web links, and web beacons. These tools collect certain standard information that your browser sends back to our Site(s). Examples include:

  • Browser type and version;
  • Address of the website from which you arrived at our Site;
  • Your Internet Protocol (IP) Address: this is a number automatically assigned to your computer or device whenever you connect to the Internet. It is a unique address assigned by your Internet service provider or IT department on a TCP/IP network. Among other things, the IP address allows web servers to locate and identify your device; and
  • Clickstream Behavior: this includes the pages you view and the links you click.

These tools help make your visit to our Sites easier, more efficient, and more valuable by providing you with a customised experience and recognising you when you return.

Use of Google Analytics and Other Backend Analytics Tools

We use Google Analytics, a service that transmits our Site traffic to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with other data held by Google. We use reports and data provided by Google Analytics and other website traffic tracking services to help us understand our Site traffic trends and usage. For more information regarding how Google collects and processes data, please visit www.google.com/policies/privacy/partners.

Do Not Track Option

Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the Diana Group Sites you visit, instructing that you do not want your online activities to be tracked. Be aware that this is different from blocking or deleting cookies. Browsers with “do not track” features enabled may still accept cookies. Diana Group Sites do not currently recognise and respond to “do not track” signals. If we do in the future, we will describe how in this Privacy Policy.

Diana Group Cookie Policy

To learn more about how to update your choices in relation to Cookies and other web browsing technologies, please go to the Diana Group Cookies Policy.

Personal Information Use Summary

Personal Information you provide to us is used either to respond to requests that you make or to aid us in serving you better. A summary of the ways we may use your Personal Information is set forth below:

  • To create and secure your client account;
  • To create your candidate profile;
  • To identify you as a user in our system;
  • To optimise and improve our Sites and services;
  • To deliver Solutions and services you request;
  • To send you administrative email notifications;
  • To respond to and track progress of your inquiries;
  • To detect, investigate, and prevent illegal or non-compliant activities;
  • To make phone calls to you, from time to time, to solicit feedback or provide secondary fraud protection; and
  • To market Diana Group and/or third party services of possible interest to you on our applicable Sites.

Sharing Your Personal Information with Third Parties

We may share your Personal Information with third parties for the purposes of operating our business, delivering, improving, and customising our Sites and Solutions, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law or otherwise with your consent. We may share Personal Information in the following ways:

  • Within Diana Group and any of our subsidiaries or affiliates for purposes of data processing, storage, and/or marketing;
  • With business partners, service vendors, or contractors to provide a requested Site content or enhancements, a Solution, a service or a transaction. Examples include, but are not limited to: processing of orders and credit card transactions, hosting websites, customer and faculty relationship management, hosting event and program planning and registration, assisting with sales-related efforts or post-sales support, delivering content, Solutions, or services, and providing customer support;
  • With service vendors focused on the provision, payment, and auditing of employee, vendor, contractor, faculty and moderator benefits;
  • With search engine, web analytics, and survey providers engaged to track trends and other statistics to enhance the user and member experience;
  • In connection with, or during negotiations of, any merger, sale of Diana Group assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company;
  • In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation or legal process;
  • With law enforcement officials, government authorities, or other third parties as necessary to comply with legal process or meet national security requirements; protect the rights, property, or safety of Cisco, its business partners, you, or others; or as otherwise required by applicable law.
  • In aggregated, anonymised, and/or de-identified form which cannot reasonably be used to identify you; and/or
  • If we otherwise notify you and you consent to the sharing.

Diana Group Sites and select Solutions use interfaces with social media sites such as Instagram, Facebook, LinkedIn, Twitter and others. If you choose to “like” or share information from Diana Group Sites or Solutions through these services, you should review the privacy policy of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your Personal Information.

International Transfers of Your Personal Information

Diana Group is headquartered in the UK and in Italy. We aim to collect and transfer Personal Information only: i) with your consent; ii) to perform a contract with you; or iii) to fulfil a compelling legitimate interest in a manner that does not outweigh your rights and freedoms. By providing us with your Personal Information, you acknowledge and agree that we may from time to time transfer any of your Personal Information to any of our offices, agents, partners, or appointed representatives located around the world.

Your Rights and Choices Regarding Your Personal Information

Diana Group encourages you to keep your Personal Information accurate and current. In addition, you have the right to ask us not to process your Personal Information for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us.
Where you have consented to us using your Personal Information, you can withdraw that consent at any time. If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it. You may request that we erase that Personal Information or cease processing it, subject to certain exceptions. You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any Personal Information we hold about you.
You may also request information about: i) the purpose of the processing; ii) the categories of Personal Information concerned; iii) who else other than Diana Group might have received the Personal Information; iv) what the source of the information was (if you didn’t provide it directly to us); and v) how long it will be stored. Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format. Reasonable access to a record of your Personal Information will be provided at no cost on request made on our Personal Information Access Request Form. If access cannot be provided within a reasonable time frame, we will provide you with an estimated date when a record of the Personal Information will be provided. If for some reason we cannot supply you with a record of the Personal Information we have collected, used, and/or stored, we will provide an explanation as to why we cannot provide the record. If you have a complaint about how we have handled your Personal Information, you may be able to ask us to restrict how we use it while your complaint is resolved. In some circumstances you can ask us to erase your Personal Information:

  • by withdrawing your consent for us to use it;
  • if it is no longer necessary for us to use your Personal Information;
  • if you object to the use of your Personal Information and we don’t have a good reason to continue to use it; or
  • if we haven’t handled your Personal Information in accordance with our obligations.

Security of Your Personal Information

Diana Group intends to protect the Personal Information entrusted to us and treat it securely in accordance with this Privacy Policy. Diana Group implements various physical, administrative, and technical measures designed to protect your Personal Information from unauthorised access, use or disclosure. We contractually require our critical suppliers, consultants and vendors to protect such information from unauthorised access, use and disclosure. We restrict access to your Personal Information to those who need to know that information to provide Solutions or other benefits to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities. If you are a candidate registered with us, we require you to enter a password to access Personal Information associated with your Diana Group account. Please do not disclose your account password to unauthorised people. Note, however, that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we use reasonable efforts to protect your Personal Information, we cannot ensure or warrant the security of any Personal Information you provide to us.

Retention of Personal Information

We will retain your Personal Information for the period required to fulfil the purposes for which it has been collected. These purposes may include the need to fulfil various commercial and legal requirements. Key requirements driving the need for collection, analysis and storage of Personal Information may include for example:

  • Business strategy;
  • Resource planning;
  • Legal compliance;
  • Financial reporting;
  • Dispute resolution; and/or
  • Asset protection and agreement enforcement.

Your Personal Information is stored by Diana Group on servers of the cloud-based database management services we engage, located primarily in the United States. Unless you request otherwise, we will retain data for the duration of your business relationship with us or for as long as is required by law. For more information on where and how long your Personal Information is stored, please contact privacy@dianagroup.it

Changes to this Privacy Policy

By using this Site and/or Solutions, you agree to the terms and conditions contained in this Privacy Policy and Terms of Use and/or any other agreement that we might have with you. If you do not agree to any of these terms and conditions, you should not use this Site or Solution. We may revise this Privacy Policy on occasion. If we make any material changes to the way we intend to use your Personal Information we will notify you by sending you an email to the last email address you provided to use and by prominently posting the changes on our Sites. Changes will be effective no later than thirty (30) days following notification. You are responsible for making certain that we have your current email address on file. If the email address we have on file is invalid, our dispatch of the email to your last known email address along with posting the notice of material Policy changes on our Sites will constitute effective notice of the changes. If you do not wish to permit the changes in the use of your Personal Information, you must notify us prior to the effective date of the changes. Continued use of our Services following notice will indicate your acknowledgement of and agreement to be bound by the changes until such time that you notify us you would like to deactivate your account and/or have your Personal Information deleted as set forth in the “How to Contact Us” section of this Policy.

How to Contact Us

Questions about this Privacy Policy Should you have any queries regarding this Privacy Policy or how your information is collected, used and stored, please contact privacy@dianagroup.it or contact us at the following location or via telephone at:
Diana Group
9 Orme Court, W24RL London, UK
+44 020 77929593
+39 06 68301775

Cookies Policy

Diana Group (“we”, “us”, “our”) takes your privacy very seriously, including your activities in browsing Diana Group owned or controlled websites: www.nannybutler.com ; www.sigillus.com ; www.supremepa.com (collectively, “Sites”). Our Sites use cookies and similar technologies for various purposes including to distinguish you from other users of our Sites. By continuing to use our Sites, you agree to our Cookie Policy.

Why and How Do We Use Cookies?

Cookies do lots of different jobs, like letting you navigate between web pages efficiently, remembering your preferences, and generally improving your experience of our Sites.
They can also help to ensure that advertisements and content you see online are more relevant to you and your interests.
The cookies used on the Sites have been categorised based on function. Here are the main types of cookies we use and why we use them:

  • Essential Cookies
    These cookies are necessary in order to enable you to move around our Sites and use their features, such as accessing secure areas of our Sites. Without these cookies services you may have asked for, cannot be provided.
  • Performance Cookies
    These cookies collect information about how you use our Sites. For instance, they tell us which pages you visit most often, and if you receive any error messages from our web pages. These cookies do not identify you. All information they collect is aggregated and therefore anonymous. We use these cookies to measure and analyse how our customers use our Sites and to improve their functionality and the user experience.
  • Functionality Cookies
    These cookies allow our sites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, personalised features. These cookies can also be used to remember changes you have made to customisable parts of our Sites. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
  • Targeting & Advertising Cookies
    These cookies are used to deliver marketing and communications more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of advertising campaign.

What Cookies Do We Use?

Cookies are text files containing small amounts of information. They are downloaded to your computer or device when you visit a Site. They don’t tell us who you are but they do enable us to recognise your device and where you have made various preferences or actions they enable us to remember them.

Disabling Cookies

Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the Sites you visit, instructing that you do not want your online activities to be tracked. Be aware that this is different from blocking or deleting cookies. Browsers with “do not track” features enabled may still accept cookies. Diana Group Sites do not currently recognise and respond to “do not track” signals. If we do in the future, we will describe how in our Privacy Policy and this Cookie Policy.

Changes to our Cookie Policy

We may change this Cookie Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and in some cases by adding notices on our homepage or other Sites or sending you email updates.

Contact Us

If you have any questions about our Cookie Policy you can contact us at: privacy@dianagroup.it