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Personal Information means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (Anonymous Information).
We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:
● Identity information includes first name, last name, username or similar identifier, date of birth and gender.
● Contact information includes email addresses, postal addresses and telephone numbers.
● Transaction information includes details about payments to and from you and other details of the services you have purchased from us.
● Profile information includes purchases made by you, your interests, preferences, feedback and survey responses.
● Marketing and communications information includes your preferences in receiving marketing materials from us and your communication preferences.
We do not collect any Special Categories of Personal Information about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, and genetic and biometric information. Nor do we collect any information about criminal convictions and offences.
Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have purchased from us, but we will notify you if this is the case at the time.
How the Personal Information Is Collected
We use different methods to collect information from and about you, including through:
● Direct interactions. You may give us your name, contact details and other information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Information you provide when you:
- enquire about our services;
- create an account on our website;
- subscribe to our service or publications;
- request marketing materials to be sent to you;
- enter a competition, promotion or survey; or
- purchase our products and services or give us feedback.
● Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this Personal Information by using cookies, server logs and other similar technologies.
● Third party or publicly available sources. We may receive Personal Information about you from third parties and public sources as set out below:
(a) Technical information from analytics providers such as Google based outside the EU;
(b) Technical information from advertising networks based inside and/or outside the EU; and
(c) Technical information from search information providers based inside and/or outside the EU.
How the Personal Information Is Used
We will only use your Personal Information in the following circumstances:
● Where we need to perform the contract we are about to enter into or have entered into with you.
● Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
● Where we need to comply with a legal obligation.
We will not sell, trade or rent any Personal Information. However, if our business enters into a joint venture with, or is sold to, or merged with, another business entity, Personal Information may be used by, and disclosed to, our new business partners or owners.
We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising.
Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage and Profile Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing communication.
You can ask us to stop sending you marketing messages at any time by opting out of receiving those messages or by emailing email@example.com. Where you opt out of receiving these marketing messages, this will not apply to Personal Information provided to us as a result of a service purchase, product/service experience or other transactions. We will not knowingly send any marketing or other material to a child.
Change of purpose
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of Your Personal Information
We will only disclose Personal Information:
● if you have given your permission; or
● if we are required to disclose Personal Information by any applicable law, regulation or legal process.
When you agree to our Registration Terms and Conditions, you give us permission to hold Personal Information on our computers and to allow our employees, agents, sub-contractors and suppliers access to it so that we and they can provide your chosen products/services.
We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances, you can ask us to delete your information. See below for further details.
In some circumstances, we will anonymise your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under certain circumstances, you have rights under information protection laws in relation to your Personal Information. You have the right to:
1. Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
2. Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
3. Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your Personal Information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:
● If you want us to establish the information's accuracy.
● Where our use of the information is unlawful but you do not want us to erase it.
● Where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims.
● You have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at firstname.lastname@example.org.
No Fee Usually Required
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What We May Need from You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at email@example.com.
Performance of Contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your Personal Information where it is necessary for compliance with a law.
April 2020 Edition