1    Introduction

1.1 These websites, vanguard-method.com, vanguard-method.net and subscription.vanguard-method.com (“Websites”), are owned and operated by Vanguard Consulting Limited (“Vanguard”, “us” or “we”) whose registered office is Villiers House, 1 Nelson Street, Buckingham, MK18 1BU, United Kingdom, company number 2207133. Our VAT number is 485 8122 22.  These are the details which the Data Protection Act 1998 says we have to give you as “Data Controller”. The term “you” or “your” refers to the user or viewer of these Websites.

1.2 We use WordPress.com to host our Websites and to manage the content on them. WordPress.com is owned by Automattic Inc, 132 Hawthorne Street, San Francisco, CA 94107, United States of America.  Details of their Cookie Policy can be found here.

1.3 This is our Privacy and Cookies Policy (“Policy”) and it has been developed in accordance with our legal obligations, including the Data Protection Act 1998, further details about which can be found on the Information Commissioner’s website at https://ico.org.uk/.

1.4 The Policy sets out:

1.4.1    the basis upon which we will process any personal data that we collect from you when you access the Websites;

1.4.2    what cookies we use on the Websites and why.

2    Your privacy

2.1    Please read this Policy carefully in conjunction with our General Terms and Conditions, as they govern your use of these Websites. By accessing the Websites, you accept the Policy and you consent to the use of your information as described in it. If you do not accept the Policy, you do not have permission to access these Websites and please do not do so.

2.2    From time to time we may review and change the Policy and, if so, we will post any revisions on these Websites. We recommend that you regularly review any changes, as you accept them by accessing the Websites.

3    What information is being collected and how is it being used?

There are various sections of the Websites, for which we collect different information. What we collect and how we use it is as follows:

3.1    As you browse the Websites, we use cookies to collect information about your use of the Websites, including traffic and location data, for example, which pages you have visited, how long you stay online and where you are located.  Further information about our use of cookies is set-out below.   Further information about how WordPress.com use cookies is set-out here.

3.2    Each time you use the internet, an Internet Protocol (“IP”) address is assigned to your computer from the Internet Service Provider. Each time your computer requests information from our Websites, your IP address is logged on our server.  We may use this in order to gather information about the traffic and usage of the Websites.

3.3    If you subscribe to our Subscriber content, or you make an enquiry about it, you will know what information is being collected through these processes when you provide the required details. We may keep details such as your name, address, telephone number, email address, job title, username, or any other login details.  We keep this information to enable us to fulfil your subscription requirements.

3.4    If you contact us, or otherwise voluntarily provide us with your name, e-mail address, job title or other contact details (whether as a subscriber or not), we may keep a record of them.

3.5 We may also keep a record of any correspondence between us, details of transactions you carry out through the Websites, details of your visits to the Websites and the resources you use, information about your computer (such as browser operating system), or other devices you have used to access the Websites.

3.6 We may use all information collected under 3.1, 3.2, 3.3, 3.4, and 3.5 above (“Personal Information”)  to:

3.6.1 contact you in response and/or to update our records;

3.6.2 contact you to notify you about changes to our service or new services;

3.6.3 undertake user profiling;

3.6.4 present content from the Websites effectively to you;

3.6.5 carry out any contracts we have with you.

4    How long do we keep the Personal Information we collect?

We keep your Personal Information only for as long as necessary to fulfil our obligations to you and to protect our legal interests or as is otherwise stated to you when such personal information is collected.

5    What are cookies?

5.1    Cookies are small text files which a website may put on your computer or mobile device when you visit a website. They are used to store information, such as when you visit a particular page, to help us to give you a better experience of using the Websites.  We will not be able to identify who you are but we will be able to identify where you are located.  This information helps us learn things such as which pages are most, and least, attractive to our visitors. It can help us to improve navigation and design features to help you access information more easily.

5.2    The list below shows the cookies we, or WordPress.com, use on our Websites. It does not show any cookies used by third party websites that we may link to.  We are entitled to change the list from time to time:

wpc_wpc: this cookie maps Vanguard’s custom domain (vanguard-method.net) to our WordPress.com website

wordpress_test_cookie: this cookie tests to see if the browser that a user is using to view the website has cookies enabled

wordpress_logged_in_*: this indicates the logged-in status of the user viewing the website

wordpress_eli: this cookie is only used when a user is logged into their WordPress.com account.  It asks whether the user has logged in in the last 2 years and reduces the number of display adverts for repeat visitors.  Users who do not have a WordPress.com account will not see this cookie.

tk_tc: this cookie collects metrics about the users use of the website related to the WordPress.com features so that WordPress.com can improve their services

tk_ni: this cookie collects metrics about the users use of the website related to the WordPress.com features so that WordPress.com can improve their services

_utmz: this cookie is used by Google Analytics to collect data about user’s use of the site, how they arrived on the site, and where the user is located when viewing the site.

_utma: this cookie is used by Google Analytics to collect data about user’s use of the site, how they arrived on the site, and where the user is located when viewing the site.

5.2.1  In addition, on the subscription.vanguard-method.com Website, the following cookie is used:

eucookielaw: this cookie checks to see whether an EU cookie law banner has been displayed.  Once the user has hidden the banner, this cookie prevents the banner from being displayed to the same user again for 30 days.

6    Removing or blocking cookies

You can choose to accept or decline cookies at any time.  Your internet browser has tools that allow you to remove, disable or block them. However, depending on which cookies you affect, the Websites may stop working, or certain features may stop working correctly.

7    To whom will Personal Information be disclosed?

7.1    Other than as expressly agreed by you, or stated when data is collected, or within this Policy, we will not disclose your personal information to anyone except that:

7.1.1   We may provide all Personal Information supplied or collected on the Websites to our contractors (including WordPress.com) and advisors, as necessary in order solely that they can enable us to exercise our rights or fulfil our obligations in relation to that personal data in accordance with this Policy.

7.1.2 We may use all Personal Information supplied or collected on the Websites by us or by WordPress.com to enforce our legal rights and to protect against unauthorised access, use, activity and/or copying, either personally by you or through third party contractors and advisors, and/or to protect the rights, property or personal safety of other users of the Websites and the public, or if we have a legal obligation to disclose your Personal Information.  This may involve using any details supplied by you including your name and contact details.

7.1.3 We may use all Personal Information supplied or collected on the Websites by us or by WordPress.com for the purpose of fraud protection and credit risk reduction.

7.1.4 If we want to buy or sell any business (including our own) we can disclose your Personal Information to the potential buyer or seller.

7.1.5 We can disclose Personal Information to other businesses in our group, which means our subsidiaries, our ultimate holding company and its subsidiary as defined in Section 1159 of the UK Companies Act 2006.

8    How Personal Information is stored and protected

8.1    Your Personal Information is stored in our databases, or those of our contractors, which are only available to the Websites’ administrators of those databases and selected people they or we designate in order to enable us to exercise our rights or fulfil our obligations in relation to that Personal Information in accordance with this Privacy and Cookies Policy on a password protected basis. 

8.2    We take steps to protect your Personal Information and to make sure it is secure against unauthorised access and use (for example, by hackers).  Despite our best efforts, and the efforts of many others, the transmission and storage of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your information transmitted to our Websites and any transmission is at your own risk. We exclude legal responsibility for any loss to you, or anybody else, incurred in this way.

8.3    We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil orders and deal with payment. By giving us your Personal Information you agree to this arrangement. We will do what we reasonably can to keep your data secure and in accordance with this privacy policy.

9    Controlling your Personal Information

9.1    If you have previously agreed to us using your Personal Information to alert you to news and events, you may change your mind at any time by contacting us here.

9.2    You may request details of Personal Information which we hold about you under the Data Protection Act 1998. A small fee may be payable. If you would like a copy of the Personal Information held on you please contact us here.

9.3    If you believe that any Personal Information we are holding on you is incorrect or incomplete, please contact us here as soon as possible. We will promptly correct any Personal Information found to be incorrect.

10    External Links

These Websites may contain links to other websites that are not owned and operated by us, such as You Tube and Twitter. These links are provided for your convenience and an inclusion of any link does not necessarily mean that we endorse that linked website, its content or operator. The content on linked websites is not published on our Websites; it is delivered using devices and services provided by the linked websites. We have no control over the functionality of those websites or their content and we accept no legal responsibility for any loss or damages that may arise from your use of them. This Policy does not apply to those websites and you may wish to review the privacy policy for each website you visit.

11    Contact us

If you have any questions or comments about this Policy or this Website, please contact Vanguard here.