Privacy Policy

1 Introduction

1.1 We are pledged to the safeguarding of privacy to [our website visitors and service users].

1.2 With regards to the personal data of [our websites visitors and service users], we act as a data controller, to regulate the purposes of the processing of personal data.

1.3 Cookies are used on our website. We will ask permission to the use ofour cookies on the first visit to our website, as those cookies may not be imperative for the provisions of [our website and services].

1.4 Privacy controls are incorporated on our website, which alters the processing of your personal data. You can specify if you would like to receive marketing communications and limit the publication of your information with the privacy controls. Privacy controls can be accessed via [URL]

1.5 The terms “we”, “us” and “our” used in this policy refer to [data controller name]. For more information about us, see Section 13.

2. How we use your personal data

2.1 Section 2 contains

(a) generic categories of processing personal data;

(b) the purposes of processing personal data;

2.2

(c) the source and categories of data, where in the event we have obtained personal data indirectly from you;

(d) the legal footing of the processing.

2.3 We may process “usage data”. The usage data may consist of information about the timing, frequency and pattern of your service use, as well as your IP address, geographical location, operation system, browser type and version, referral source, length of visit, page views and website navigation paths. Usage data may be processed in the purpose of website and service analysis. Our legitimate interests, monitoring and improving the website, is the legal basis for this processing.

2.4 “Account data” may be processed on the use of our website. The account data may include your name and email address. For the purposes of providing our services, performance of our website, the safeguarding of our website and services, uphold back-ups of our databases and communication with you. Our legitimate interests, the administration of our website and business, is the legal basis for this processing.

2.5 We may process “publication data” on the use of our website. Publication data is information you put for publication through our services or on our website. Processing of this data may occur to facilitate such publication and management of our website and services. Our legitimate interests, the administration of our website and services, is the legal basis for this processing.

2.6 “Enquiry data” may be processed with the use of our website. Enquiry data is information in any enquiry you submit to us in regards to our website and services. Processing of this enquiry data may occur for marketing, selling and general ability of our services. Our legitimate interests, the administration of our website and services, is the legal basis for this processing.

2.7 “Transaction data” may be processed. Processing of this transaction data may occur for the purpose of supplying the services purchased and to keep records of those transactions. Transaction data is information associated with transactions you have made through/on our website for services we provide. Transaction data may include your card details, transaction details and contact details. Our legitimate interests, the administration of our website and services, is the legal basis for this processing.

2.8 “Notification data” may be processed with the use of our website. Notification data is information you give to us when subscribing to our services or our website. Processing of this notification data may occur to transmit the applicable notifications in regards to the use and services of our website. Our legitimate interests, the correspondence of our website and services, is the legal basis for this processing.

2.9 Processing of any of your personal data described in this policy may occur where necessary for the purposes of defence of legal claims, whether administrative, in court proceedings or out-of-court procedure. The protection of your legal rights, the legal rights of others and our legal rights, our legitimate interests is the legal basis for this processing.

3. Providing your personal data to others

3.1 Disclosure of your personal data may be given to our professional advisers for the necessary purposes of managing risks, obtaining or maintaining insurance coverages, defence of legal claims, in court and out of court or administrative procedures.

3.2 Our hosting services providers [URL] servers will store all personal data held in our website database.

3.3 Inclusion to the disclosures listed in section 3, where the establishment is compelled, we may disclose your personal data to comply with legal obligations, or to protects your interests and others, where necessary to protect the establishment of legal claims, in court and out of court or administrative procedures.

4. Retaining and deleting personal data

4.1 Our policies and procedures are listed out in this section 4, to ensure that we are compliant with the legal requirements in regards to the retention and deleting of personal data.

4.2 Your personal data that we process is kept no longer than the necessary purpose of those purposes. Retention of your personal data is as follows:

(a) usage data will be retained for a minimum period of 1 year upon date of collection and a maximum period of 5 years following that date;

(b) account data will be retained for a minimum period of 1 year upon date of collection and a maximum period of 5 years following that date;

(c) publication data will be retained for a minimum period of 1 year from the date of when the relevant publications were made through/on our website, and for a maximum period of 5 years following that date;

(d) enquiry data will be retained for a minimum period of 1 year upon date of enquiry and a maximum period of 5 years upon that date;

(e) transaction data will be retained for a minimum period of 1 year upon date of transactions and a maximum period of 5 years upon that date;

(f) notification data will be retained for a minimum period of 1 year upon the date we are instructed to cease to sending the notifications, and for a maximum period of 5 years upon that date;

4.4 In acceptance to the other provisions listed out in Section 4, where necessary to comply with legal obligations, to protect the interests of you and the interest of others, we may retain your personal data.

5. Your rights

5.1 The rights you have under data protection law are listed in this Section 5;

5.2 Your principle rights under data protection law are as follows;

(a) the right to access – you can ask for copies of your personal data to be provided;

(b) the right to rectification or revision – you can ask us to rectify or revise any incorrect or incomplete personal data;

(c) the right to deletion – you can ask to delete or erase your personal data;

(d) the right to restrict processing – you can ask to restrict the use of your personal data

(e) the right to objection – you can object to the use of your personal data;

(f) the right to data portability – you can ask us to transmit your personal data to another establishment;

(g) the right to complain to supervisory authority – you can complain about our processing of your personal data;

5.3 Limitations and exceptions are subjected to these rights. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to- data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/. You may exercise any of your rights to us, in regards to your personal data, using the contact details below.

6 About cookies

6.1 A cookie is a file containing a string of letters and numbers called an “identifier” that is by a web server to a web browser and then stored by the browser. The identifier is then sent back to the server every time the browser requests a page from the server.

6.2 There are two types of cookies; one is a “persistent” cookie, which will be stored by a web browser and will remain active until its expiry date, unless deleted by the user; The other is a “session” cookie, this type of cookie automatically deletes itself once the web browser has been closed.

6.3 Information obtained and stored in cookies may be linked to personal data we have stored about you, but typically cookies do not contain any information that personally identifies a user.

7. Cookies Cookies used by our service providers

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

7.2 We use Google Analytics, Google Analytics uses cookies to gather information about the use of our website.

7.3 You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.

8. Managing cookies

8.1 You can usually refuse and delete cookies from most websites. How to do so vary from browser to browser, and from version to version. You can get up-to-date information about blocking and deleting cookies via these links:

(a) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari);

(b) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete- manage-cookies (Internet Explorer);

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(e) https://support.google.com/chrome/answer/95647 (Chrome);

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and- privacy (Edge);

8.2 Blocking cookies can have a negative impact on the performance of a website.

8.3 Most websites features will become inoperative if you disable/block the cookies.

9. Amendments

9.1 This policy may be updated from time to time and will be republished on our website.

9.2 To ensure you are happy with any changes we may make to the policy, you should check the page frequently.

9.3 We may notify you of significant changes to this policy via email.

10. Amendments

10.1 This website is owned and operated by [name].

10.2 We are registered in [England and Wales] under registration number [number],

10.3 Our principal place of business is at [address].

10.4 You can contact us:

(a) [by post, to [the postal address given above]];

(b) [using our website contact form];

(c) [by telephone, on [the contact number published on our website]]; or

(d) [by email, using [the email address published on our website]]. [additional list items]

11. Data protection officer

11.1 Our data protection officer's contact details are: [contact details].