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Introduction

As a Data Controller and Data Processor, we collect, handle and store data related to individuals. As such, we are committed to safeguarding the privacy of our general customers, our website visitors and website creation service users; in this policy we explain how we will handle your personal data.

We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. This is an explicit acceptance. We will provide a link to a reliable website to give you information to help you to change your cookie settings if you do not wish to accept cookies from our website. You can read our cookie policy here.

Personal Data that we collect, the provcessing method and the nature of what personal data we collect.

Analytics

Processing Method : Google Analytics : Used to collect web interactions.

Personal Data: Cookies and Usage data.

Managing Contacts and Sending Messages

Processing Method : Microsoft Outlook : Used for day to day email communications and email address management.

Personal Data: various types of data including names and e-mail addresses.

Processing Method : Elastic Email : Used for sending e-mail messages in bulk as part of our marketing communications to our customers.

Personal Data: E-mail Addresses and Usage Data including message reading and links clicked.

User Database Management

Processing Method : Microsoft Access : Used to store, manipulate and report on our customers

Personal Data: names, e-mail addresses, postal addresses, telephone numbers, mobile numbers.

Processing Method : Sage Instant Accounts : used to store and manage our commercial and invoicing processes

Personal Data: names, e-mail addresses, postal addresses and telephone numbers.

Interaction with live chat platforms

Processing Method : Tawk.To : used for allowing occasional real-time and online chat sessions between customers and our helpdesk.

Personal Data: name and e-mail address and IP address.

How we use your personal data - more detail.

In this section we set out:

  1. the general categories of personal data that we may process;
  2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
  3. the purposes for which we may process personal data; and
  4. the legal bases of the processing.
  5. Categories of personal data that we may process

With respect to visiting our website, we may process data about your use of our website and services, ("usage data"). The usage data may include your IP address, approximate geographical location, browser type and version, operating system, referral source,(how you reached our website) , length of visit, pages views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system provided by Google. This usage data may be processed for the purposes of analysing the use of the website and our services. The legal basis for this processing is our legitimate interests, namely, monitoring and improving our website and services.

With respect to our relationships with you as a customer, we may process your account data ("account data"). The account data will normally include your name and email address as an absolute minimum. Additional data ("profile data") that we may process in respect to your identification can include your postal address, telephone or mobile phone number. The source of the account data is provided directly by you when you establish a relationship with us at a business level. The account data may be processed for the purposes of providing our services and communicating with you about the nature of the services that we provide for you.  The legal basis for this processing is your consent by virtue of you placing an order with those to fulfil work for you and also our legitimate interests, namely the proper administration of our business relationship with you and therefore the performance of any contract between you and us.

We may process personal data that are provided in the course of the use of our services ("service data"). The service data may include web addresses, router IP addresses, hosting account credentials, database credentials. The source of the service data is from you but, where you are in a contract with us, we create aspects of this service data on your behalf because of a technical nature of the creation process. The service data may be processed for the purposes of operating your website, providing our services, ensuring the security of your website and services associated with the website, maintaining back-ups of your files and databases and communicating with you. The legal basis for this processing is your consent and our legitimate interests, namely the proper administration of your website and the performance of a contract between you and us.

We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The data gathered as part of enquiry data will include your name, your e-mail address, any information which you provide within the enquiry, your IP address, a time when the enquiry was made. The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you and to the purposes of responding to sales of technical queries. The legal basis for this processing is your consent and / or our legitimate interests, namely the proper administration of your website and the performance of a contract between you and us.

We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, generally limited to your name, e-mail address and postal address and phone number. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and our legitimate interests, namely our interest in the proper administration of our business at a commercial level.

We may process information that you may provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent and the performance of a contract between you.

We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate business interests, namely the proper administration of our website and business and communications with users.

We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal request or obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Providing your personal data to others

We may disclose your personal data to any member of our business insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

We may disclose profile data and transaction data to our accountant insofar as reasonably necessary for the purposes of obtaining professional advice and managing our financial obligations.

We may disclose profile data on our website insofar as reasonably necessary for the purposes of displaying testimonial quotations, expressly given to us by you and with your permission to do so. The only data so shown will be your name and your business name.

Financial transactions relating to our website and services are handled by our payment services providers, HSBC Bank and PayPal UK. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with issues and queries relating to such payments and refunds. We may also share transaction data  with our payment services providers as well as other data related to you for the purposes of managing your website services to you. This is particularly relevant for setting up new website domains where we need to include information about you when creating domain.

In addition to the specific disclosures of personal data set out in this section, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

International transfers of your personal data

In this section we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

We have no offices, facilities or subcontractors in countries outside the European Economic Area (EEA). As such no personal data will be transferred outside of the EAA.

The hosting facilities for our website are situated in the United Kingdom. As such no personal data will be transferred outside of the EAA.

You acknowledge that personal data that you submit for publication through our website may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

Retaining and deleting personal data

This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain and delete your personal data as follows:

Usage Data will be retained for a period of 12 months, at the end of which period it will be deleted from our systems.

Account data will be retained for a period of 5 years, at the end of which period it will be deleted from our systems unless your business relationship with us extends past that time.

Profile data will be retained for a period of 5 years, at the end of which period it will be deleted from our systems unless your business relationship with us extends past that time.

Service data will be retained for a period of 5 years, at the end of which period it will be deleted from our systems unless your business relationship with us extends past that time.

Enquiry data will be retained for a period of 5 years, at the end of which period it will be deleted from our systems unless your business relationship with us extends past that time.

Transaction data will be retained for a period of 5 years, at the end of which period it will be deleted from our systems unless your business relationship with us extends past that time.

Notification data will be retained for a period of 5 years, at the end of which period it will be deleted from our systems unless your business relationship with us extends past that time.

Correspondence data will be retained for a period of 5 years, at the end of which period it will be deleted from our systems unless your business relationship with us extends past that time.

Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Amendments

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy.

We may notify you of changes to this policy by email or through the private notification system on our website.

Your rights

In this section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries below. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

You may exercise any of your rights in relation to your personal data by written notice to us.

Policy Date and Status

This policy has been updated to take full account of the GDPR.

Date: 12 January 2018