- 1. Appendix
- 2. Background
- 3. Definitions and Interpretation
- 4. What Does This Policy Cover?
- 5. What is Personal Data?
- 6. What Are My Rights?
- 7. What Data Do We Collect?
- 8. How Do You Use My Personal Data?
- 9. How Long Will You Keep My Personal Data?
- 10. How and Where Do You Store or Transfer My Personal Data?
- 11. Do You Share My Personal Data?
- 12. How Can I Control My Personal Data?
- 13. Can I Withhold Information?
- 14. How Can I Access My Personal Data?
- 16. How Do I Contact You?
|Date of Publication:||21.01.19|
|Policy Creator:||BWAR LIMITED|
[ ] understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, [ ] We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
3. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of the Site;|
|“Cookie”||means a small text file placed on your computer or device by the Site when you visit certain parts our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
4. What Does This Policy Cover?
5. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
6. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data wehold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contactus using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we use it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
7. What Data Do We Collect?
Depending upon your use of our Site, we may collect some or all of the following personal and non-personal:
- Date of birth;
- Email address;
- Telephone number;
- Business name;
- Job title;
- Payment information;
- Information about your preferences and interests;
- IP address;
- Image Uploads;
- Web browser type and version;
- Operating system;
8. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to ouruse of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for one of the following purposes:
- Providing and managing your Account;
- Providing and managing your access to ourSite;
- Personalising and tailoring your experience on our Site;
- Supplying our servicesto you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by contacting us by [Email Address]).
- Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone and/or text message and/or post with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
Third Parties whose content appears on our Site may use third-party Cookies, as detailed below in Part 13. Please refer to Part 13 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 15.
9. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);
If you want to know how your personal data is stored, you can ask us for by contacting us via [Email address], [Telephone number].
10. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
Where we transfer your data to a third party based in the US, this may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.
Please contact us via [Email Address] or [Telephone Number] further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
- SSL certificate
- Password secured database
- Strong passwords to enhance website security
11. Do You Share My Personal Data?
Wewill not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
Wemay sometimes contract with the following third parties to supply certain services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that wehold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR.
In some limited circumstances, wemay be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
12. How Can I Control My Personal Data?
- In addition to your rights under the GDPR, set out in Part 5, whenyou submit personal data via ourSite, you may be given options to restrict ouruse of your personal data. In particular, We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing via [Email address], [Telephone number].
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
13.Can I Withhold Information?
You may access certain areas of ourSite without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.
14.How Can I Access My Personal Data?
If you want to know what personal data wehave about you, you can ask us for details of that personal data and for a copy of it via [Email address], [Telephone number].
By using our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other thanus.
All Cookies used by and on our Site are used in accordance with current Cookie Law.
Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand howour Site is used. This, in turn, enables us to improve our Site and the services offered through it.
The analytics service(s) used by our Site use(s) Cookies to gather the required information. You do not have to allow usto use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our Site, it does enable us to continually improve our Site, making it a better and more useful experience for you.
For further details on which cookies are used on the site, please consult our site please contact the developer of the site by email [firstname.lastname@example.org].
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
16.How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use one of the following details. [Email address], [Telephone number].
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.