Updated: 17th January 2020
Maintaining your privacy and your trust is very important. We strive to be especially clear on how we use your personal information if and when we collect it, and on the ways in which we can work together to protect your privacy.
This document is for compliance with the Data Protection & Privacy legislation.
What products and services are covered by this policy?
For the purposes of the data protection & privacy legislation the Data Controller is:
|Data Protection (Charges and Information) Regulations 2018
We are have not registered with the supervisory authority; we rely on the exemption under the legislation, as we only process personal data for our own:
- Advertising, marketing and public relations
- Accounts and records
Purpose and legitimate interest.
How do we use the information we collect?
We may use the information we collect for a variety of purposes, including to:
|Lawful Basis of Processing:
General Personal Data:
1. Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
2. Processing is necessary for compliance with a legal obligation to which the controller is subject.
3. Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
4. Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
5. The data subject has given consent to the processing of his or her personal data for one or more specific purposes. Consent may be withdrawn at any time.
Special Category Personal Data
We do not process special category or criminal conviction data.
|Categories of personal data and Sources
What information do we collect from you, and how is it used?
You can visit our website without telling us who you are and without revealing any personal information about yourself. To provide full service however and if contacting us directly by other means, we will most often need to collect some personal information. For instance, we collect information about you when you complete and online form, register for an account and when you create or modify your personal data for one of our Services. The types of Information we collect may include:
We do not facilitate processing personal data of data subjects under the age of consent (children (13)).
From cookies: We may also collect “cookie” information that we may save to your computer or electronic device. If you do not accept cookies, you may not be able to use all functionality of our on-line Services.
Logs: We may record certain information and store it in log files when you interact with our Services. This information may include Internet protocol (IP) or other device addresses or ID numbers as well as browser type, Internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, your mobile carrier, and system configuration information.
Analytics: We and our analytics providers also collect and store analytics information when you use our Services to help us improve our Services. We make sure this data is anonymous by not connecting any analytics data to personally identifiable data such as a name, email address, physical address, or phone number.
Social Media: We operate social media business pages such as Facebook for Business. While acting as operator of these pages with those third-parties we only process aggregated data which cannot directly identify you. Therefore, if exercising your right to access your personal information in this regard as the data subject, and to allow these third parties time to reply within the legislative time-frame, you should click the link(s) in the data processor information section below.
Public sources: Personal data may be obtained from public registers (such as Companies House), news articles, sanctions lists, and Internet searches.
|How might we share information?
We are not in the business of selling your personal information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your personal information with third party data processors, as set forth below:
With your consent: We will not share your personal information with companies, organisations, or individuals who are not associated with us unless we have your affirmative consent to do so.
Payment Processing: We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use billing information except for the sole purpose of credit card processing.
Newsletter Service: We use a commercial application to facilitate our newsletter service.
Where we are required to do so under statutory obligation: HMRC, Accountants and other professional service organisations
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights: We may disclose your information (including your personal information) to a third party if:
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. We will notify you of such a change in ownership or transfer of assets by posting a notice on our website.
The data controller does not transfer personal data outside of the United Kingdom or European Union, unless indicated below.
All data processors acting on behalf of the data controller have appropriate safeguards in place. For example, those operating in the USA, are signed up to the EU-US Privacy Shield.
Data Processor Information
The following third-party service providers are used by us and only process data in accordance with the instructions from the data controller:
How long will we keep the personal data?
Retaining some data may be subject to a statutory retention period and this must be adhered to, (to keep certain data for a minimum period of time). This may include personal data (name, address, contact details), but on expiry of such statutory requirement, such data will be destroyed securely. Where possible any personally identifiable data will be anonymised or pseudonymised.
Your information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information. Our backup routine keeps data for a rolling 30-day period after which time the data is removed from all systems.
|Statutory or other requirements
The data controller does not process personal data in respect of any statutory requirement, nor require personal data to be supplied as part of any contractual agreement, however in respect of the controller’s services, certain communications may not be possible without such personal data being supplied, for example an email to furnish with updates information etc. or an address to fulfil an order.
Profiling and Automated Decision Making
No profiling or automatic decision-making processes are undertaken by the data controller in respect of any personal data processing activities.
Consent may be withdrawn at any time.
Your fundamental rights as a Data Subject are:
Under the right of access (2), you have the right to have:
- confirmation that your data is being processed;
- access to your personal data; and
- other supplementary information
So that you are aware of and can verify the lawfulness of the processing.
Your right to access can be exercised by contacting the data controller as above.
Not all fundamental rights are absolute.
|Your right to complain to the supervisory authority/regulator
You have the right to complain about organisations processing your personal data. You can exercise this right by contacting the supervisory authority of the data controller as follows:
Information Commissioner's Office
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number