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Privacy policy

1.
Introduction
Commitment to privacy
1.1
We are committed to safeguarding the privacy of
our website visitors and service users
.
Document applies to controlled personal data
1.2
This policy
applies where we are acting as a data controller with respect to the personal data of
our website visitors and service users
; in other words, where we determine the purposes and means of the processing of that personal data.
Consent to use of cookies
1.3
We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of
our website and services
, we will ask you to consent to our use of cookies when you first visit our website.
Website privacy controls
1.4
Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can
specify whether you would like to receive direct marketing communications and limit the publication of your information
. You can access the privacy controls via
URL
.
Data controller name
1.5
In
this policy
, "we", "us" and "our" refer to
data controller name
.
For more information about us, see
Section 13
.
2.
Credit
Docular credit
2.1
This document was created using a template from Docular (https://docular.net).
Free documents licensing warning
You must retain the above credit. Use of this document without the credit is an infringement of copyright. However, you can purchase from us an equivalent document that does not include the credit.
3.
How we use your personal data
Introduction to categories, purposes and legal bases of processing
3.1
In
this Section 3
we have set out:
  1. the general categories of personal data that we may process;
  2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data
    ;
  3. the purposes for which we may process personal data; and
  4. the legal bases of the processing.
Processing of usage data
3.2
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
consent
or
our legitimate interests, namely
monitoring and improving our website and services
or
specify basis
.
Processing of account data
3.3
We may process
your website user 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
consent
or
our legitimate interests, namely
the proper administration of our website and business
or
the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
or
specify basis
.
Processing of publication data
3.4
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
consent
or
our legitimate interests, namely
the proper administration of our website and business
or
the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
or
specify basis
.
Processing of enquiry data
3.5
We may process
information contained in any enquiry you submit to us regarding goods and/or services
("enquiry data"). The enquiry data may be processed
for the purposes of offering, marketing and selling relevant goods and/or services to you
. The legal basis for this processing is
consent
or
our legitimate interests, namely
the proper administration of our website and business
or
the performance of a contract between you and us and/or the taking steps, at your request, to enter into such a contract
or
specify basis
.
Processing of transaction data
3.6
We may process
information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website
("transaction data").
The transaction data may include
your contact details, your card details and the transaction details
.
The source of the transaction data is
you and/or our payment services provider
.
The transaction data may be processed
for the purpose of supplying the purchased goods and/or services and keeping proper records of those transactions
. The legal basis for this processing is
the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract; providing that, if you are not the person contracting with us, the legal basis for this processing is our legitimate interests, namely
the proper administration of our website and business
or
specify basis
.
Processing of notification data
3.7
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
or
our legitimate interests, namely
communications with our website visitors and service users
or
the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
or
specify basis
.
Processing of other data
3.8
We may process
identify general category of data
.
This data may include
list specific items of data
.
The source of this data is
identify source
.
This data may be processed for
specify purposes
. The legal basis for this processing is
consent
or
our legitimate interests, namely
specify legitimate interests
or
the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
or
specify basis
.
Processing for legal claims
3.9
We may process
any of your personal data identified in
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
.
Processing for risk management
3.10
We may process
any of your personal data identified in
this policy
where necessary for
the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice
. The legal basis for this processing is our legitimate interests, namely
the proper protection of our business against risks
.
General purposes of processing personal data
3.11
In addition to the specific purposes for which we may process your personal data set out in
this Section 3
, 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.
Disclosure of third party personal data
3.12
Please do not supply any other person's personal data to us, unless we prompt you to do so.
4.
Providing your personal data to others
Disclosure of personal data to insurers etc
4.1
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, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure
.
Disclosures of personal data to hosting services providers
4.2
Your personal data held in our website database
or
Identify personal data category or categories
will be stored on the servers of our hosting services providers
identified at
URL
.
Disclosures of personal data to subcontractors
4.3
We may disclose
specify personal data category or categories
to
our suppliers or subcontractors
identified at
URL
insofar as reasonably necessary for
specify purposes
.
Disclosure of personal data necessary for legal compliance etc
4.4
In addition to the specific disclosures of personal data set out in
this Section 4
, 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.
5.
International transfers of your personal data
Introduction to international personal data transfers
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)
.
International transfers to hosting services provider
5.2
The hosting facilities for our website are situated in
specify countries
.
The European Commission has made an "adequacy decision" with respect to
the data protection laws of each of these countries
.
Transfers to
each of these countries
will be protected by appropriate safeguards, namely
the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from
source
or
specify appropriate safeguards and means to obtain a copy
.
International transfers to subcontractors
5.3
Specify category or categories of supplier or subcontractor
is
or
are
situated in
specify countries
.
The European Commission has made an "adequacy decision" with respect to
the data protection laws of each of these countries
.
Transfers to
each of these countries
will be protected by appropriate safeguards, namely
the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from
source
or
specify appropriate safeguards and means to obtain a copy
.
Publication of personal data on internet
5.4
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
Data retention introduction
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.
Personal data retention default rule
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.
Personal data retention specific rules
6.3
We will retain your personal data as follows:
  1. usage data will be retained for a minimum period of
    period
    following the date of collection, and for a maximum period of
    period
    following that date
    ;
  2. account data will be retained for a minimum period of
    period
    following the date of closure of the relevant account, and for a maximum period of
    period
    following that date
    ;
  3. publication data will be retained for a minimum period of
    period
    following the date when the relevant publication ceases to be published on our website or through our services, and for a maximum period of
    period
    following that date
    ;
  4. enquiry data will be retained for a minimum period of
    period
    following the date of the enquiry, and for a maximum period of
    period
    following that date
    ;
  5. transaction data will be retained for a minimum period of
    period
    following the date of the transaction, and for a maximum period of
    period
    following that date
    ;
  6. notification data will be retained for a minimum period of
    period
    following the date that we are instructed to cease sending the notifications, and for a maximum period of
    period
    following that date (providing that we will retain notification data insofar as necessary to fulfil any request you make to actively suppress notifications)
    ; and
  7. data category
    will be retained for a minimum period of
    period
    following
    date
    , and for a maximum period of
    period
    following
    date
    .
Personal data deletion exception
6.4
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.
Your rights
Introduction to data subject rights list
7.1
In
this Section 7
, we have listed the rights that you have under data protection law.
List of data subject rights
7.2
Your principal rights under data protection law are:
  1. the right to access - you can ask for copies of your personal data;
  2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
  3. the right to erasure - you can ask us to erase your personal data;
  4. the right to restrict processing - you can ask use to restrict the processing of your personal data;
  5. the right to object to processing - you can object to the processing of your personal data;
  6. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
  7. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
  8. 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.
Learn more about data subject rights
7.3
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/.
Exercise of data subject rights
7.4
You may exercise any of your rights in relation to your personal data
by written notice to us, using the contact details set out below
.
8.
About cookies
What are cookies?
8.1
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.
Persistent and session cookies
8.2
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.
Cookies and personal data
8.3
Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
9.
Cookies that we use
Purposes for which cookies are used
9.1
We use cookies for the following purposes:
  1. authentication and status - we use cookies
    to identify you when you visit our website and as you navigate our website, and to determine if you are logged into the website
    (cookies used for this purpose are:
    identify cookies
    )
    ;
  2. personalisation - we use cookies
    to store information about your preferences and to personalise the website for you
    (cookies used for this purpose are:
    identify cookies
    )
    ;
  3. 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
    (cookies used for this purpose are:
    identify cookies
    )
    ;
  4. advertising - we use cookies
    to help us to display advertisements that will be relevant to you
    (cookies used for this purpose are:
    identify cookies
    )
    ;
  5. analysis - we use cookies
    to help us to analyse the use and performance of our website and services
    (cookies used for this purpose are:
    identify cookies
    )
    ; and
  6. cookie consent - we use cookies
    to store your preferences in relation to the use of cookies more generally
    (cookies used for this purpose are:
    identify cookies
    )
    .
10.
Cookies used by our service providers
Use of cookies by services providers
10.1
Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
Google Analytics cookies
10.2
We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.
The relevant cookies are:
identify cookies
.
Service provider cookies (generic)
10.3
We use
identify service provider
to
specify service
. This service uses cookies for
specify purpose(s)
. You can view the privacy policy of this service provider at
URL
.
The relevant cookies are:
identify cookies
.
11.
Managing cookies
How to manage cookies
11.1
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:
  1. https://support.google.com/chrome/answer/95647 (Chrome);
  2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
  3. https://help.opera.com/en/latest/security-and-privacy/ (Opera);
  4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
  5. https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
  6. https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Negative impact of blocking cookies
11.2
Blocking all cookies will have a negative impact upon the usability of many websites.
Effects on website use of blocking cookies
11.3
If you block cookies, you will not be able to use all the features on our website.
12.
Amendments
Amendment by publication
12.1
We may update
this policy
from time to time by publishing a new version on our website.
Check for changes to Document
12.2
You should check this page occasionally to ensure you are happy with any changes to
this policy
.
Notification of changes to Document
12.3
We
may
or
will
notify you of
changes
or
significant changes
to
this policy
by email
.
13.
Our details
Website operator name
13.1
This website is owned and operated by
name
.
Company registration details
13.2
We are registered in
England and Wales
under registration number
number
, and our registered office is at
address
.
Place of business
13.3
Our principal place of business is at
address
.
Contact information
13.4
You can contact us:
  1. by post, to
    the postal address given above
    ;
  2. using our website contact form
    ;
  3. by telephone, on
    the contact number published on our website
    ; or
  4. by email, using
    the email address published on our website
    .
14.
Data protection officer
Data protection officer contact details
14.1
Our data protection officer's contact details are:
contact details
.
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