Our registered office is at 3 Greenhill Court, Greenhill, Brampton, Cumbria, CA8 1UY.
This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.
In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.
This notice applies to personal data collected through our website and through social media platforms.
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
Data Protection Officer
If you have any questions about how we process your personal data, including any requests to exercise your legal rights, please contact our DPO, Robert Coster at email@example.com.
Personal Data We Process
1. How we obtain personal data
The information we process about you includes information:
- you have directly provided to us
- as a result of monitoring how you use our website or our services
2. Types of personal data we collect directly
When you use our website, our services or buy from us, for example, if you create an account on our website, we ask you to provide personal data. This can be categorised into the following groups:
- personal identifiers, such as your first and last names, your title and your date of birth
- contact information, such as your email address, your telephone number and your postal addresses for billing, delivery and communication
- account information, including your username and password
- records of communication between us including messages sent through our website, email messages and telephone conversations
- marketing preferences that tell us what types of marketing you would like to receive
3. Types of personal data we collect from third-parties
We confirm some of the information you provide to us directly using data from other sources. We also add to the information we hold about you, sometimes to remove the need for you to provide it to us and sometimes in order to be able to assess the quality of the services you offer.
The additional information we collect can be categorised as follows:
- information that confirms your identity
- business information, including your business trading name and address, your company number (if incorporated), and your VAT number (if registered)
- information that confirms your contact information
- reviews and feedback about your business on other websites through which you sell your services
- unsolicited complaints by other users
By using our website and our services, we process:
- your username and password and other information used to access our website and our services
- information you contribute to our community, including reviews
- your replies to polls and surveys
- technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
- usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
- transaction information that includes the details of the products services you have bought from us and payments made to us for those services
- your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.
We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.
6. Special personal data
Special personal data is data 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.
It also includes information about criminal convictions and offences.
We do not collect any special personal data about you.
7. If you do not provide us with the personal data we need
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.
If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
8. Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal data.
We may use it in order to:
- verify your identity for security purposes when you use our services
- sell products to you
- provide you with our services
- provide you with suggestions and advice on products, services and how to obtain the most from using our website
9. Information we process with your consent
10. Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
- improving our services
- record-keeping for the proper and necessary administration of our business
- responding to unsolicited communication from you to which we believe you would expect a response
- preventing fraudulent use of our services
- exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
- insuring against or obtaining professional advice that is required to manage [organisational or business] risk
- protecting your interests where we believe we have a duty to do so
Sometimes, we must process your information in order to comply with a statutory obligation.
12. Information we process to protect vital interests
In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal information on the basis of vital interests.
How and when we process your personal data
13. Your personal data is not shared
We do not share or disclose to a third party, any information collected through our website.
14. Information you provide
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
In posting personal data, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal data that you have posted. You can make a request by contacting us at firstname.lastname@example.org.
15. Payment Information
Payment information is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of Stripe or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
16. Information obtained from third parties
Although we do not disclose your personal data to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal data from third parties whose services we use.
17. Service providers and business partners
We may share your personal data with businesses that provide services to us, or with business partners.
- we may pass your payment information to our payment service provider to take payments from you
- we may use fraud prevention agencies and credit reference agencies to verify your identity and we may pass your information to those agencies if we strongly suspect fraud on our website
- we may pass your contact information to advertising agencies to use to promote our services to you
Use of information we collect through automated systems
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to keep you signed in to our website
- to record your answers to surveys and questionnaires on our site while you complete them
- to record the conversation thread during a live chat with our support team
Requests by your web browser to our servers for web pages and other content on our website are recorded.
Re-marketing involves placing a ‘tracking technology’ such as a cookie, a ‘web beacon’ (also known as an ‘action tag’ or a ‘single-pixel GIF’) to track which pages you visit and to serve you relevant adverts for our services when you visit some other website.
The benefit of re-marketing technology is that we can provide you with more useful and relevant adverts, and not show you ones repeatedly that you may have already seen.
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.
We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org
22. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
With your consent, we may communicate using software provided by a third party such as Facebook (WhatsApp), Apple (Facetime), Microsoft (Skype) or Zoom Video Communications (Zoom).
If you have any concerns about using a particular software for communication, please tell us.
24. Data may be processed outside the UK
Our websites are hosted in London and Amsterdam, Netherlands.
We may also use outsourced services in countries outside the UK from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the UK.
25. Control over your own information
It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.
At any time, you may contact us to request that we provide you with the personal data we hold about you.
To obtain a copy of any information we hold about you, contact us to make that request.
When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
26. Communicating with us
When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.
We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.
If your complaint reasonably requires us to notify some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.
28. Retention period
Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:
- to provide you with the services you have requested
- to comply with other law, including for the period demanded by our tax authorities
- to support a claim or defence in court
We shall update this privacy notice from time to time as necessary.