1. WHO WE ARE
1.3 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, we would really appreciate the chance to deal with your concerns first so we would be grateful if you would contact us at email@example.com before you approach the ICO.
1.4 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.
2. PERSONAL DATA WE COLLECT ABOUT YOU
2.1 Personal data is information that relates to an identified or identifiable natural person, this means a human being. Anonymous data, where you cannot find out who the data relates to, is not personal data.
2.2 There are different kinds of data, below are some examples:
(a) Identity Data includes first name, last name, date of birth and gender.
(b) Contact Data includes address, email address and telephone numbers.
(c) Financial Data includes bank account and payment card details.
(d) Technical Data includes IP address, your login data, and your browser type.
(e) Profile Data includes your username and password and survey responses.
2.3 We may collect anonymised details about your use of the websites for the purposes of aggregate statistics or reporting purposes. Aggregated data (your data combined with other people’s data) may come from your personal data but if it does not directly or indirectly reveal your identity, it is not considered personal data. For example, we may combine and analyse your use of the website to work out the number of users accessing a specific website feature.
2.4 We do not normally collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
3. IF YOU DO NOT PROVIDE PERSONAL DATA
3.1 Where we need to collect personal data by law, or under the terms of the contract between us and you do not 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.
4. HOW DO WE COLLECT YOUR PERSONAL DATA?
4.1 We use different methods to collect data from and about you, including when you fill out a form or give us information via the phone, by post, online or by email or otherwise. Other instances where we may collect information are, when you:
(a) Visit our website or social media (e.g. through cookies);
(b) Enter a competition or promotion;
(c) Sign up for our mailing list/newsletter;
(d) Enquire about products through our Website or via phone, fax, email, post;
(e) Create an account on our website;
(f) Provide feedback;
(g) Fill in a form on our Website; and/or
(h) Otherwise contact us.
4.2 Personal information may be collected by us and by our third party service providers who assist us in operating the Website. Including:
(a) Google Analytics:
(i) We use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies. Google will store this information.
(ii) If you do not want your website visit information reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at https://tools.google.com/dlpage/gaoptout.
(b) Click Stream Information
(i) In common with many websites, when you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date and time of your visit to the Website, the pages accessed and any information downloaded. This information is used for statistical, reporting and website administration, maintenance and improvement purposes only.
5. USING YOUR PERSONAL DATA
5.1 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:
(a) Where we need to perform the contract we are about to enter into or have entered into with you.
(b) 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.
(c) Where we need to comply with a legal or regulatory obligation.
5.2 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 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.
5.3 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.
6.1 Promotional offers from us: We may use your personal data to try to understand what you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
6.2 Third-party marketing: We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
6.3 Opting out: You can ask us or third parties to stop sending you marketing messages at any time by contacting firstname.lastname@example.org at any time.
7. DISCLOSURES OF YOUR PERSONAL DATA
7.1 We do not disclose your personal information without your permission, unless the disclosure is:
(b) To our related companies;
(c) To third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; or
(d) Required or authorised by law.
8. DATA SECURITY
8.1 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.
8.2 While we take great care to protect your personal information on our Website, unfortunately no information transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us.
8.3 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.
9. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
9.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.2 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 requirements.
10. YOUR LEGAL RIGHTS
10.1 Under certain circumstances, you have rights under information protection laws in relation to your personal information. You have the right to:
(a) Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
(c) Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact email@example.com
11. NO FEE 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 may refuse to comply with your request in these circumstances.
12. 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.
13. TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may 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.
14. THIRD-PARTY LINKS