Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.
If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways:
• 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
We provide more information about the cookies we use in our cookie policy.
18. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
19. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.
We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.
Disclosure and sharing of your information
20. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
21. Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website. They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts. We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
22. Credit reference
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
23. Data may be processed outside the European Union
Our websites are hosted in the UK.
We may also use outsourced services in countries outside the European Union 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 European Union.
For example, some of the software our website uses may have been developed in the United States of America or in Australia.
We use the following safeguards with respect to data transferred outside the European Union:
• the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
• the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union , specifically that in the country of the UK.
• we comply with a code of conduct approved by a supervisory authority in the European Union, specifically that in the country of the UK.
• we are certified under an approved certification mechanism as provided for in the Act.
• both our organisation and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information. Control over your own information
24. Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
25. Access to your personal information
At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
To obtain a copy of any information that is not provided on our website you should contact us to make that request.
After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
26. Removal of your information
If you wish us to remove personally identifiable information from our website, you should contact us to make your request.
This may limit the service we can provide to you.
27. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Other matters
28. Use of site by children
We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our website only with consent from a parent or guardian
We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.
29. 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.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
30. How you can complain
If you are not happy with our privacy policy or if you have any complaint then you should tell us.
If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
31. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information 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.
32. Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.
However, ultimately it is your choice as to whether you wish to use our website.
33. Review of this privacy policy
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy policy, please contact us.
Explanatory notes
Privacy policy notice
General notes
The EU Data Protection Directive (95/46/EC), implemented as the General Data Protection Regulation, or the GDPR, came into force from 25 May 2018.
In the UK, the rights and obligations that the GDPR brought are written into a new law called the Data Protection Act 2018. The Act remains in force even after the UK leaves the European Union.
The requirements under the new law are similar in extent to prior data protection law in the UK. If your business complies with prior law, then the changes you need to make are likely to be small.
The possible implications for non-compliance are now much more severe. In theory, the Information Commissioner’s Office (the ICO) has the power to fine a business 4% of its annual worldwide turnover.
However, as with other EU law regarding selling to consumers we believe that the ICO in practice is unlikely to fine many small businesses and organisations without having first given a warning. Having a privacy notice (such as one based on this template) that shows some effort to comply with the law is likely, in our opinion, to generate enough goodwill with the ICO to avoid a fine in the first instance.
Updating your website privacy notice is not the only requirement for compliance with the Act. You are also likely to need to change how customers and visitors can access personal data held about them, and create new procedures for obtaining compliance to collect and use personal data.