Privacy Policy
[company_name] are a UK based company, whose registered offices are located at [company_registered_address].
Website(s)
[company_url]
Collectively, all parties and websites identified above are hereafter referred to as “[company_nickname]”, “our” or “we”.
Introduction
At [company_nickname] we regard your privacy as important. We may collect information about you via our websites. We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our websites (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.
Purpose of this privacy policy
This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up as a provider, member or subscribe to our blog. This website is not intended for use by anyone under the age of 18 years and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other policies we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and policies and is not intended to override them.
Controller
[company_nickname] is the controller and responsible for your personal data (collectively referred to as “[company_nickname]”, “we”, “us” or “our” in this privacy policy). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below:
[company_name]
[company_contact_name]
[company_email]
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review and this policy is subject to change. You should refer to this policy at least once a year to remain updated. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
- Contact Data includes billing address, delivery address, email address and telephone numbers;
- Financial Data includes bank account and payment card details;
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and
- versions, operating system and platform, and other technology on the devices you use to access this website;
- Profile Data includes your username and password, your interests, preferences, feedback, comments, posts and survey responses;
- Usage Data includes information about how you use our website, products and services; and
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Special Categories of Personal Data: within the GDPR these include; details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), or any information about criminal offences, alleged or convicted.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is Your Personal Data Collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This
- includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy and other terms here for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
– analytics providers such as Google;
– advertising networks; and
– search information providers. - Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
- Third-Party ProcessorsWe use the following categories of third-parties to process your data and deliver services for the purposes shown. All of these processors have access to some of your Personal data as appropriate for the delivery of the purpose specified.
- Processor Category Purpose
- Management/Moderators Service management, monitoring & accounting
- Technical Management Website technical & support services
- Hosting Secure data centre & hosting services
- Software Development Service development & improvement
- Online Services Website apps & features for members; and
- Payment Service Providers Telecom PSP, credit/debit card PSP, banking & other financial services
How We use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us here: [company_email].
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer:
(a) Identity
(b) Contact
Performance of a contract with you:
(a) Identity
(b) Contact
To process and deliver your order including:
– Manage payments, fees and charges
– Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(f) Performance of a contract with you
(g) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
– Notifying you about changes to our terms or privacy policy
– Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(e) Performance of a contract with you
(f) Necessary to comply with a legal obligation
(g) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(e) Performance of a contract with you
(f) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(d) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(e) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business) Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information and you have not opted out of receiving that marketing.
Third-party marketing
We will not share your information with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by emailing: [company_email]. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy here.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by email at [company_email]. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to merge with other organisations. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International Transfers
We may share or transfer your personal data outside of the European Economic Area (EEA) only if we enable users to create accounts from outside of the United Kingdom. If ever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Please contact us if you want further information on the specific mechanism used by us if/when transferring your personal data out of the EEA.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further information. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
GDPR: Individual Rights Description
If you wish to exercise any of the rights set out above, please contact us as follows.
Revoke your consent – in accordance with the GDPR, to revoke consent for processing of your Personal data send an email with the word “Revoke” in the subject field to: [company_email]. Data Subject Access Request (DSAR) – in accordance with the GDPR, you may exercise any of the 8 rights shown above by emailing a DSAR to [company_email]. No fee is usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
Under the GDPR we are obliged to respond to any DSAR within 30-days. While it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
What is Lawful Basis?
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
The full list of our Agreements and Policies can be found on our website: [company_url]
E&OE: If you notice any errors (spelling, grammar or other) in this policy document please feel free to notify us via email: [company_email]
For any questions relating to your personal data, or to submit a Data Subject Access Request ‘DSAR’, please contact our Data Protection Department:
Address: [company_registered_address]
Email: [company_email]