Introduction
We are committed to safeguarding the privacy of our website visitors and services customers.
This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
The personal data that we collect
In this section we have set out the general categories of personal data that we process.
Contact Data – We may process data enabling us to get in touch with you. The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
Enquiry Data – We may process information contained in any enquiry you submit to us regarding products or services.
Account Data – We may process your user account data. The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
Communication Data – We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
Usage Data – We may process data about your use of our website and services. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking systems.
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Purposes of processing and legal bases
In this section we have set out the purposes for which we may process personal data and the legal bases of the processing.
Operations – We may process your personal data for the purposes of operating our website and putting website users in contact with relevant services providers. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
Relationships and communications – We may process contact data, enquiry data, account data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users, the maintenance of relationships, and the proper administration of our website, services and business.
Personalisation – We may process enquiry data, account data and/or usage data for the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is our legitimate interests, namely offering the best possible experience for our website visitors and service users.
Direct marketing – We may process contact data, enquiry data and/or account data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
Research and analysis – We may process enquiry data, usage data and/or communication data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Providing your personal data to others
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
In this section we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).
The personal data we collect may be transferred to and stored in countries outside the UK and the European Union. This will typically occur when service providers are located outside the UK and the European Union or if you are based outside the UK and the European Union. These transfers are subject to special rules under data protection laws.
Some of these jurisdictions require different levels of protection in respect of personal data and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will ensure that your personal data is only used in accordance with this Notice and applicable data protection laws and is respected and kept secure and where a third party processes your personal data on our behalf we will ensure that one of the following safeguards is implemented: we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the UK and the European Union; and
- where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe Union and the US.
Our directors and other individuals working for us may in limited circumstances access personal data outside of the UK and European Union if they are on travelling outside of the UK or European Union. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to the same legal protections that would apply to accessing personal data within the UK.
In limited circumstances the people to whom we may disclose personal data as mentioned in
Providing your personal data to others above may be located outside of the UK and European Union. In these cases, we will impose any legally required protections to the personal data as required by law before it is disclosed.
For further details please contact us by using the details set out in the
“Contact us” section of our website.
Retaining and deleting personal data
This section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
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
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Your rights
In this section we have listed the rights that you have under data protection law.
Your principal rights under data protection law are:
- the right to access – you can ask for copies of your personal data;
- the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
- the right to erasure – you can ask us to erase your personal data;
- the right to restrict processing – you can ask us to restrict the processing of your personal data;
- the right to object to processing – you can object to the processing of your personal data;
- the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
- the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
- the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting
https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
You may exercise any of your rights in relation to your personal data by
contacting us.
Third party websites
Our website includes hyperlinks to, and details of, third party websites.
In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
Our website and services are targeted at persons over the age of 18.
If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
Updating information
Please
let us know if the personal information that we hold about you needs to be corrected or updated.
