v1_6, last updated 11 May 2018
While ‘personal data’ is a defined term in EU law, we use it here to also cover ‘personally identifiable information’ as defined in US law, and other similar legal definitions. Essentially ‘personal data’ means any information relating to an identified or identifiable natural person, namely one who can be identified, directly or indirectly from that information alone or in conjunction with other information.
This Policy sets out what personal data we might collect, how we process and protect that data, the lawful grounds for that processing, and your related rights. In most cases, the lawful ground will be that the processing: (i) is necessary for our legitimate interests in carrying out our business, including to grow and improve our Services, provided those interests are not outweighed by your rights and interests (‘Legitimate Interests’), (ii) is necessary to perform a contract with you (‘Contract’), or (iii) is necessary to comply with our legal obligations (‘Legal Obligation’). Where processing is based on your consent (‘Consent’), we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent.
As data protection law and practice are constantly developing, we’ll need to update this policy from time to time, which we’ll do by posting a new policy on the Website that takes effect from the date stated. It is your responsibility to return to the Website from time to time and check for changes.
How Do We Obtain Personal Data?
We might collect or be provided personal data in the normal course of business, for example:
We are the ‘controller’ of Account, Improvement and Marketing Data and we are the ‘processor’ of Service Data – the customer remains the ‘controller’ of Service Data. We do not collect or retain any debit or credit card data ourselves. Any such data is collected and processed by our payment processors to process the relevant payments and we and those processors will at all times comply with the applicable industry codes and laws regarding security and retention of such data, for example the Payment Card Industry Data Security Standard. When you provide us with personal data about yourself or another person, you are confirming to us that you are authorised to provide us with that information and that any personal data you give us is accurate and up-to-date. Provision of personal data to us is never a requirement, however if you do not provide us with the personal data necessary for us to carry out an action at your request or under a contract with or relating to you, for example to respond to your query or provide Services to you, we may not be able to respond to your query or provide Services to you.
Sensitive Personal Data
How do we use personal data?
We use personal data in the ‘normal course’ of our business, including to provide and improve our Services and to meet any binding contractual or legal obligations. For example:
Sharing Data & International Transfers
We will not give, sell or rent your personal data to third parties so they can market their services to you. Nor do we accept advertising from third parties on the Website. We may share personal data in the following limited circumstances.
In each case, we have written contracts in place incorporating relevant wording to safeguard that personal data and comply with applicable laws, and we will only share such data as is necessary for the purpose in question. Where possible, we keep personal data within the European Economic Area (‘EEA’). However in order to carry out the above purposes, we may use third parties and their facilities outside the EEA. In all such cases we will ensure that appropriate security measures are in place to protect your personal data and a valid legal basis for the transfer applies.
As a default position, we will only retain personal data for any statutory retention period, then a reasonable period (if any) for the above purposes. This is subject, for example, to any valid opt-out or withdrawal of consent where processing is based on consent, or other valid exercise of your data subject rights.
The security of data is very important to our business. In accordance with our legal obligations, we take appropriate technical and organisational measures to protect your personal data and keep those measures under review. However, we can only be responsible for systems that we control and we would note that the internet itself is not inherently a secure environment.
Third Party Services
You have the right to know if we process any personal data about you and, if we are, with certain limitations, to a copy of that personal data. You also have the right to ask us to remove or correct any of that personal data that is inaccurate, to object to certain processing and to withdraw any consent you may have given us for any processing of your personal data. As from 25 May 2018, you will also have the right to ask us to restrict processing certain of your personal data, to erase your personal data, and to ‘port’ certain of your personal data to you or another provider, provided in each case that we have such data and certain conditions are met.
You have the right, at any time, to object to the processing of your personal data for direct marketing.
‘Do Not Track’
The Website and Services do not use technologies that respond to ‘Do-Not-Track’ signals communicated by your internet browser.
If you’ve any question you can always contact us at the address above or by email to email@example.com. You have the right, at all times, to notify a complaint to any regulator such as the UK Information Commissioner, although we would welcome the opportunity to discuss and resolve any complaint with you first.