Privacy Policy

1. Introduction
1.1 We are committed to safeguarding the privacy of our clients.

1.2 This policy applies where we are acting as a data controller with  respect to the personal data of our clients; in other words, where we  determine the purposes and means of the processing of that personal  data.

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.

1.4 In this policy, “we”, “us” and “our” refer to the owners of this website. For more information about us, see Section 13.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.

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 Google Analytics.  This usage data may be processed for the purposes of analyzing 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.

3.3 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. 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.

3.4 We may process information that you post for publication on our  website or through our services (“publication data”). The publication  data may b 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.

3.5 We may process information contained in any inquiry you submit to  us regarding goods and/or services (“inquiry data”). The inquiry 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.

3.6 We may process information relating to our customer  relationships, including customer contact information (“customer  relationship data”).[ The customer relationship data may include your  name, your employer, your job title or role, your contact details, and  information contained in communications between us and you. The source  of the customer relationship data is you. The customer relationship data  may be processed for the purposes of managing our relationships with  customers, communicating with customers, keeping records of those  communications and promoting our products and services to customers. The  legal basis for this processing is our legitimate interests, namely the  proper management of our customer relationships.

3.7 We may process information relating to transactions, including  purchases of goods and 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 transaction data may be processed for the purpose of  supplying the purchased goods and 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 and our legitimate  interests, namely the proper administration of our business and  services.

3.8 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.

3.9 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.

3.10 We may process any of your personal data identified in this  policy where necessary for the establishment, exercise or defense 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.

3.11 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.

3.12 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.

3.13 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

4.1 We may disclose your personal data to any member of our group of  companies (this means our subsidiaries, our ultimate holding company and  all its subsidiaries) insofar as reasonably necessary for the purposes,  and on the legal bases, set out in this policy.

4.2 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 defense  of legal claims, whether in court proceedings or in an administrative  or out-of-court procedure.

4.3 We may disclose your inquiry 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 inquiry  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 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 defense of legal claims, whether in court proceedings or in an  administrative or out-of-court procedure.

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 The hosting facilities for our website are situated in the United  States of America. 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.

5.3 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 We will retain your personal data as follows:
(a) All personal data categories listed previously in this policy  document will be retained for a minimum period of 6 months and for a  maximum period of 5 years.

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. 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 significant changes to this policy by email.

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. You can access your personal data by contacting us  through the website’s contact form.

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; you object to the processing under certain  rules of applicable data protection law; the processing is for direct  marketing purposes; and the personal data have been unlawfully  processed. However, there are exclusions of the right to erasure. The  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 defense 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 defense 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 defense 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  defense 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:
(a) consent; or
(b)  that the processing is necessary for the performance of a contract to  which you are party or in order to take steps at your request prior to  entering into a contract, 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. ]

9. About cookies

9.1 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.

9.2 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.

9.3 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.

10. Cookies that we use

10.1 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) personalization – we use cookies to store information about your preferences and to personalize the 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 analyze the use and performance of our website and services;
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally;

11. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyze 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/.[ The relevant  cookies are: [identify cookies].]

11.3 We publish Google AdSense interest-based advertisements on our  website. These are tailored by Google to reflect your interests. To  determine your interests, Google will track your behavior on our website  and on other websites across the web using cookies. You can view,  delete or add interest categories associated with your browser by  visiting: https://adssettings.google.com. You can also opt out of the  AdSense partner network cookie using those settings or using the Network  Advertising Initiative’s multi-cookie opt-out mechanism  at: ttp://optout.networkadvertising.org. However, these opt-out  mechanisms themselves use cookies, and if you clear the cookies from  your browser your opt-out will not be maintained. To ensure that an  opt-out is maintained in respect of a particular browser, you may wish  to consider using the Google browser plug-ins available at:  https://support.google.com/ads/answer/7395996.[ The relevant cookies  are: [identify cookies].]

12. Managing cookies

12.1 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-cookieswebsite-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internetexplorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-andprivacy(Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

13. Our details

13.1 Please use the contact form on our website to:
– get in touch with our Data Protection Officer for any inquiries
– obtain details of any registered company
– request a copy of any information held about you