1.
Introduction
1.1 We
are committed to safeguarding the privacy of our website visitors and service
users; in this policy we explain how we will handle your personal data.
1.2 By
using our website and agreeing to this policy, you consent to our use of cookies
in accordance with the terms of this policy.
2.
How we use your personal data
2.1 In
this Section 2 we have set out:
(a)
the general categories of personal data that we may process;
(b) in
the case of personal data that we did not obtain directly from you, the source
and specific categories of that data;
(c)
the purposes for which we may process personal data; and
(d)
the legal bases of the processing.
2.2 We
may process data about your use of our website and services (“usage data“). 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 system. This usage data may be processed for the purposes of analysing
the use of the website and services. The legal basis for this processing is our
legitimate interests, namely monitoring and improving our website and services.
2.3 We
may process your account data (“account
data“). The account data may include your name and email
address. The source of the account data is you or your employer. The account
data may be processed for the purposes of operating our website, providing our
services, ensuring the security of our website and services, maintaining
back-ups of our databases and communicating with you. The legal basis for this
processing is our legitimate interests, namely the proper administration of our
website and business.
2.4 We
may process your information included in your personal profile on our website
(“profile data“).
The profile data may include your name, address, telephone number, email
address, profile pictures, gender, date of birth, relationship status,
interests and hobbies, educational details and employment details. The profile
data may be processed for the purposes of enabling and monitoring your use of
our website and services. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.
2.5 We
may process your personal data that are provided in the course of the use of
our services (“service data“).
The service data may include both company and personal information. The source
of the service data is you or your employer. The service data may be processed
for the purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business.
2.6 We
may process information that you post for publication on our website or through
our services (“publication data“).
The publication data may be processed for the purposes of enabling such
publication and administering our website and services. The legal basis for
this processing is our legitimate interests, namely the proper administration
of our website and business.
2.7 We
may process information contained in any enquiry you submit to us regarding
products and/or services (“enquiry
data“). The enquiry data may be processed for the purposes of
offering, marketing and selling relevant products and/or services to you. The
legal basis for this processing is consent.
2.8 We
may process information that you provide to us for the purpose of subscribing
to our email notifications and/or newsletters (“notification data“). The notification data may be
processed for the purposes of sending you the relevant notifications and/or
newsletters. The legal basis for this processing is consent.
2.9 We
may process information contained in or relating to any communication that you
send to us (“correspondence data“).
The correspondence 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. The
correspondence data may be processed for the purposes of communicating with you
and record-keeping. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business and
communications with users.
2.10
We may process any of your personal data identified in the other provisions of
this policy 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.
2.11
In addition to the specific purposes for which we may process your personal
data set out in this Section 2, we may also process any of 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.
2.12
Please do not supply any other person’s personal data to us, unless we prompt
you to do so.
3.
Automated decision-making
3.1 We
will use your personal data for the purposes of automated decision-making in
relation to our website and our marketing & sales processes.
3.2
This automated decision-making will involve marketing personalisation across
our website and other marketing communications such as email.
3.3
The significance and possible consequences of this automated decision-making
are that you are likely to receive a personalised experience with content and
other marketing assets.
4.
Providing your personal data to others
4.1 We
may disclose your personal data to our insurers and/or professional advisers
insofar as reasonably necessary for the purposes of obtaining and maintaining
insurance coverage, managing risks, obtaining professional advice and managing
legal disputes.
4.2 We
may disclose personal data to our suppliers or subcontractors insofar as
reasonably necessary for them to complete any marketing or sales activity we
have set out for them on our behalf.
4.3 We
may disclose your enquiry data to one or more of those selected third party
suppliers of goods and services identified on our website for the purpose of
enabling them to contact you so that they can offer, market and sell to you
relevant goods and/or services. Each such third party will act as a data
controller in relation to the enquiry data that we supply to it; and upon
contacting you, each such third party will supply to you a copy of its own
privacy policy, which will govern that third party’s use of your personal data.
4.4 In
addition to the specific disclosures of personal data set out in this Section
4, we may also 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.
5.
International transfers of your personal data
5.1 In
this Section 5, we provide information about the circumstances in which your
personal data may be transferred to countries outside the European Economic
Area (EEA).
5.2 We
have offices and facilities in the UK. In the future we may add additional
offices. The European Commission has made an “adequacy decision” with respect to
the data protection laws of The UK. Transfers to other countries will be
protected by appropriate safeguards, namely the use of standard data protection
clauses adopted or approved by the European Commission OR the use of binding
corporate rules.
5.3
The hosting facilities for our website are situated in The UK. The European
Commission has made an “adequacy decision” with respect to the data protection
laws of The UK. Transfers to other countries will be protected by appropriate
safeguards, namely the use of standard data protection clauses adopted or
approved by the European Commission.
5.4
All of our marketing and sales departments are situated in The UK. The European
Commission has made an “adequacy decision” with respect to the data protection
laws of The UK. Transfers to other countries will be protected by appropriate
safeguards, namely the use of standard data protection clauses adopted or
approved by the European Commission.
5.5
You acknowledge that personal data that you submit for publication through our
website or services may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.
6.
Retaining and deleting personal data
6.1
This Section 6 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.
6.2
Personal data that we process for any purpose or purposes shall not be kept for
longer than is necessary for that purpose or those purposes.
6.3
Your personal data will be retained for 2 years following the date and time of
your last interaction with our website or business, at the end of which period
it will be deleted from our systems.
6.4 In
some cases it is not possible for us to specify in advance the periods for
which your personal data will be retained. In such cases, we will determine the
period of retention based on the following criteria:
(a)
the period of retention of personal data will be determined based on your
interaction with our website or business.
6.5
Notwithstanding the other provisions of this Section 6, 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.
7.
Amendments
7.1 We
may update this policy from time to time by publishing a new version on our
website.
7.2
You should check this page occasionally to ensure you are happy with any
changes to this policy.
7.3 We
may notify you of changes to this policy by email or through the private
messaging system on our website.
8.
Your rights
8.1 In
this Section 8, we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of the details have
been included in our summaries. Accordingly, you should read the relevant laws
and guidance from the regulatory authorities for a full explanation of these
rights.
8.2
Your principal rights under data protection law are:
(a)
the right to access;
(b)
the right to rectification;
(c)
the right to erasure;
(d)
the right to restrict processing;
(e)
the right to object to processing;
(f)
the right to data portability;
(g)
the right to complain to a supervisory authority; and
(h)
the right to withdraw consent.
8.3
You have the right to confirmation as to whether or not we process your
personal data and, where we do, access to the personal data, together with
certain additional information. That additional information includes details of
the purposes of the processing, the categories of personal data concerned and
the recipients of the personal data. Providing the rights and freedoms of
others are not affected, we will supply to you a copy of your personal data.
The first copy will be provided free of charge, but additional copies may be
subject to a reasonable fee.
8.4
You have the right to have any inaccurate personal data about you rectified
and, taking into account the purposes of the processing, to have any incomplete
personal data about you completed.
8.5 In
some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: the personal data are no
longer necessary in relation to the purposes for which they were collected or
otherwise processed; you withdraw consent to consent-based processing; the
processing is for direct marketing purposes; and the personal data have been
unlawfully processed. However, there are certain general exclusions of the
right to erasure. Those general exclusions include where processing is
necessary: for exercising the right of freedom of expression and information;
for compliance with a legal obligation; or for the establishment, exercise or
defence of legal claims.
8.6 In
some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the
personal data; processing is unlawful but you oppose erasure; we no longer need
the personal data for the purposes of our processing, but you require personal
data for the establishment, exercise or defence of legal claims; and you have
objected to processing, pending the verification of that objection. Where
processing has been restricted on this basis, we may continue to store your
personal data. However, we will only otherwise process it: with your consent;
for the establishment, exercise or defence of legal claims; for the protection
of the rights of another natural or legal person; or for reasons of important
public interest.
8.7
You have the right to object to our processing of your personal data on grounds
relating to your particular situation, but only to the extent that the legal
basis for the processing is that the processing is necessary for: the
performance of a task carried out in the public interest or in the exercise of
any official authority vested in us; or the purposes of the legitimate
interests pursued by us or by a third party. If you make such an objection, we
will cease to process the personal information unless we can demonstrate
compelling legitimate grounds for the processing which override your interests,
rights and freedoms, or the processing is for the establishment, exercise or
defence of legal claims.
8.8
You have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you
make such an objection, we will cease to process your personal data for this
purpose.
8.9
You have the right to object to our processing of your personal data for
scientific or historical research purposes or statistical purposes on grounds
relating to your particular situation, unless the processing is necessary for
the performance of a task carried out for reasons of public interest.
8.10
To the extent that the legal basis for our processing of your personal data is
consent, and such processing is carried out by automated means, you have the
right to receive your personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply where it would
adversely affect the rights and freedoms of others.
8.11
If you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state
of your habitual residence, your place of work or the place of the alleged
infringement.
8.12
To the extent that the legal basis for our processing of your personal
information is consent, you have the right to withdraw that consent at any
time. Withdrawal will not affect the lawfulness of processing before the
withdrawal.
8.13
You may exercise any of your rights in relation to your personal data by
written notice to us or via our contact form, in addition to the other methods
specified in this Section 8.
9.
Third party websites
9.1
Our website includes hyperlinks to, and details of, third party websites.
9.2 We
have no control over, and are not responsible for, the privacy policies and
practices of third parties.
10.
Personal data of children
10.1
Our website and services are targeted at persons over the age of 18.
10.2
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.
11.
Updating information
11.1
Please let us know if the personal information that we hold about you needs to
be corrected or updated.
12.
Acting as a data processor
12.1
In respect of payment data we do not act as a data controller; instead, we act
as a data processor.
12.2
Insofar as we act as a data processor rather than a data controller, this
policy shall not apply. Our legal obligations as a data processor are instead
set out in the contract between us and the relevant data controller.
13.
About cookies
13.1 A
cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.
13.2
Cookies may be either “persistent” cookies or “session” cookies: a persistent
cookie will be stored by a web browser and will remain valid until its set
expiry date, unless deleted by the user before the expiry date; a session
cookie, on the other hand, will expire at the end of the user session, when the
web browser is closed.
13.3
Cookies do not typically contain any information that personally identifies a
user, but personal information that we store about you may be linked to the
information stored in and obtained from cookies.
14.
Cookies that we use
14.1 We use cookies for the following
purposes:
(a)
authentication – we use cookies to identify you when you visit our website and as
you navigate our website;
(b)
status – we use cookies to help us to determine if you are logged into our
website;
(c)
personalisation – we use cookies to store information about your preferences
and to personalise our website for you;
(d)
security – we use cookies as an element of the security measures used to
protect user accounts, including preventing fraudulent use of login
credentials, and to protect our website and services generally;
(e)
advertising – we use cookies to help us to display advertisements that will be
relevant to you;
(f)
analysis – we use cookies to help us to analyse the use and performance of our
website and services and
(g)
cookie consent – we use cookies to store your preferences in relation to the
use of cookies more generally.
15.
Cookies used by our service providers
15.1
Our service providers use cookies and those cookies may be stored on your
computer when you visit our website.
15.2
We use Google Analytics to analyse the use of our website. Google Analytics
gathers information about website use by means of cookies. The information
gathered relating to our website is used to create reports about the use of our
website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
16.
Managing cookies
16.1
Most browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date information about blocking and deleting
cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome)
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox)
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera)
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer)
(e) https://support.apple.com/kb/PH21411 (Safari)
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge)
16.2
Blocking all cookies will have a negative impact upon the usability of many
websites.
16.3
If you block cookies, you will not be able to use all the features on our
website.
17.
Our details
17.1
You can contact us:
(a) by
post, using the postal address.
(b)
using our website contact form.
(c) by
telephone, on the contact number published on our website from time to time; or
(d) by
email, using the email address published on our website from time to time.
