Last Updated October 7, 2018
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Data we Collect about You.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity of the individual has been removed, referred to as anonymous data.
Identity Data includes first name, last name, username or similar identifier, title, and gender.
Contact Data includes billing address, delivery address, email address, and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions,
operating system and platform, and other technology on the devices you use to access this website.
Profile Data includes purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data includes information about how you use our website, products, and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
How is Your Personal Data Collected?
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our services, subscribe to our service or publications, request marketing to be sent to you; or give us feedback or contact us.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
(a) analytics providers (such as Google);
(b) marketing providers (such as HubSpot); and
(c) contact, financial and transaction data from providers of technical, payment and delivery services.
How we use your personal data.
We will only use your personal data where lawful. Most commonly, we will use your personal data in the following circumstances:
(a) Where we need to perform under a contract;
(b) Where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
(c) Where we need to comply with a legal obligation.
Purposes for Which We Will Use Your Personal Data
We have set out below, in a table format, a description of the ways we use personal data, and the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process personal data for more than one lawful ground depending on the specific purpose for which we are using the data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If your data is regulated by the General Data Protection Rule (“GDPR”) where you would like to request a change, or you would like to request a change in data use, please contact us by emailing firstname.lastname@example.org.
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. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.
Change of Purpose
We will only use your personal data 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 and compliant with law. If your data is regulated by GDPR and you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by emailing email@example.com.
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 data without your knowledge or consent, in compliance with the above rules, where this is required or lawful.
Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the table above.
External Third Parties. We have legal relationships with all of these third parties and they have given us reasonable assurances that they manage your data in accordance with applicable law.
(a) Google Analytics
(e) Microsoft 365
We have put in place appropriate security measures to help prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will You use my Personal Data for?
We will only retain your personal data 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 data 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 data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
While we do not provide legal advice to you, under certain circumstances, you may have rights under data protection laws in relation to your personal data if your data is regulated by GDPR. Please email firstname.lastname@example.org if you would like to do any of the following.
(a) Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also may ask us to delete or remove your personal data 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 data 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.
(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) 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 may object where we are processing your personal data 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.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
(f) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
i. If you want us to establish the data's accuracy.
ii. Where our use of the data is unlawful but you do not want us to erase it.
iii. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
iv. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(g) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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.
(h) Withdraw consent at any time where we are relying on consent to process your personal data. 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.
No Fee Usually Required
You will not have to pay a fee to access your personal data (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 data (or to exercise any of your other rights). This is a security measure to ensure that personal data 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 Response
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.