Privacy and cookies policy

1.       Introduction

1.1    We are committed to safeguarding the privacy of [our website visitors and customers]; in this policy we explain how we will handle your personal data.

1.2    This policy applies where we are acting as a data controller with respect to [your personal data]; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can [specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data]. You can access the privacy controls via [URL].

1.4    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of [our website and services], we will ask you to consent to our use of cookies when you first visit our website.

1.5    In this policy, "we", "us" and "our" refer to [data controller name].[ For more information about us, see Section 19.]

2.       The personal data that we collect

2.1    In this Section 2 we have set out the general categories of personal data that we process[ and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data].

2.2    We may process data enabling us to get in touch with you ("contact data").[ The contact data may include [your name, email address, telephone number, postal address and/or social media account identifiers].][ The source of the contact data is [you and/or your employer].][ If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.]

2.3    We may process [your website user account data] ("account data").[ The account data may [include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences].][ The primary source of the account data is [you and/or your employer, although some elements of the account data may be generated by our website].][ If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.]

2.4    We may process [information relating to our customer relationships] ("customer relationship data").[ The customer relationship data may include [your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer].][ The source of the customer relationship data is [you and/or your employer].]

2.5    We may process [information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website] ("transaction data").[ The transaction data may include [your name, your contact details, your payment card details (or other payment details) and the transaction details].][ The source of the transaction data is [you and/or our payment services provider].]

2.6    We may process [information contained in or relating to any communication that you send to us or that we send to you] ("communication data"). The communication 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.]

2.7    We may process [data about your use of our website and services] ("usage data"). The usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page 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].

2.8    We may process [identify general category of data].[ This data may include [list specific items of data].][ The source of this data is [identify source].]

3.       Purposes of processing and legal bases

3.1    In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2    Operations - We may process [your personal data] for [the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control]. The legal basis for this processing is [our legitimate interests, namely [the proper administration of our website, services and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

3.3    Publications - We may process [account data] for [the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the publication of content in the ordinary course of our operations]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

3.4    Relationships and communications - We may process [contact data, account data, customer relationship data, transaction data and/or communication data] for [the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and compliant handling]. The legal basis for this processing is [our legitimate interests, namely [communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business]] OR [[specify basis]].

3.5    Personalisation - We may process [account data and/or usage data] for [the purposes of personalising the content and advertisements that you see on our website and through our services to ensure that you only see material that is relevant to you]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [offering the best possible experience for our website visitors and service users]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract] OR [[specify basis]].

3.6    Direct marketing - We may process [contact data, account data, customer relationship data and/or transaction data] for [the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [promoting our business and communicating marketing messages and offers to our website visitors and service users]] OR [[specify basis]].

3.7    Research and analysis - We may process [usage data and/or transaction data] for [the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [monitoring, supporting, improving and securing our website, services and business generally]] OR [[specify basis]].

3.8    Record keeping - We may process [your personal data] for [the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally]. The legal basis for this processing is our legitimate interests, namely [ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy].

3.9    Security - We may process [your personal data] for [the purposes of security and the prevention of fraud and other criminal activity]. The legal basis of this processing is our legitimate interests, namely [the protection of our website, services and business, and the protection of others].

3.10  Insurance and risk management - We may process [your personal data] where necessary for [the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice]. The legal basis for this processing is our legitimate interests, namely [the proper protection of our business against risks].

3.11  Legal claims - We may process [your personal data] 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].

3.12  Legal compliance and vital interests - We may also process your personal data where such processing 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.

4.       Automated decision-making

4.1    We will use your personal data for the purposes of automated decision-making in relation to [specify automated decisions].

4.2    This automated decision-making will involve [provide meaningful information about the logic involved].

4.3    The significance and possible consequences of this automated decision-making are [specify significance and consequences].

5.       Providing your personal data to others

5.1    We may disclose [your personal data] to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.[ Information about our group of companies can be found at [URL].]

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

5.3    [Your personal data held in our website database] OR [[Identify personal data category or categories]] will be stored on the servers of our hosting services providers[ identified at [URL]].

5.4    We may disclose [specify personal data category or categories] to [our suppliers or subcontractors][ identified at [URL]] insofar as reasonably necessary for [specify purposes].

5.5    Financial transactions relating to [our website and services] [are] OR [may be] handled by our payment services providers, [identify PSPs]. 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 complaints and queries relating to such payments and refunds]. You can find information about the payment services providers' privacy policies and practices at [URLs].

5.6    We may disclose [contact data along with any other personal data contained in enquiries made through our website or services] to [one or more of those selected third party suppliers of goods and/or services identified on our website] for [the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services].[ Each such third party will act as a data controller in relation to the personal data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.]

5.7    In addition to the specific disclosures of personal data set out in this Section 5, we may 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6.       International transfers of your personal data

6.1    In this Section 6, we provide information about the circumstances in which your personal data may be transferred to [countries outside the United Kingdom and the European Economic Area (EEA)].

6.2    We[ and our other group companies] have [offices and facilities] in [specify countries].[ The competent data protection authorities have made an "adequacy decision" with respect to [the data protection laws of each of these countries].][ Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from [source]] OR [the use of binding corporate rules, a copy of which you can obtain from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].]

6.3    The hosting facilities for our website are situated in [specify countries].[ The competent data protection authorities have made an "adequacy decision" with respect to [the data protection laws of each of these countries].][ Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which you can obtain from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].]

6.4    [Specify category or categories of supplier or subcontractor] [is] OR [are] situated in [specify countries].[ The competent data protection authorities have made an "adequacy decision" with respect to [the data protection laws of each of these countries].][ Transfers to [each of these countries] will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from [source]] OR [[specify appropriate safeguards and means to obtain a copy]].]

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

7.       Retaining and deleting personal data

7.1    This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2    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.

7.3    We will retain your personal data as follows:

(a)    [contact data will be retained for a minimum period of [period] following the date of the most recent contact between you and us, and for a maximum period of [period] following that date];

(b)    [account data will be retained for a minimum period of [period] following the date of closure of the relevant account, and for a maximum period of [period] following that date];

(c)    [customer relationship data will be retained for a minimum period of [period] following the date of termination of the relevant customer relationship and for a maximum period of [period] following that date];

(d)    [transaction data will be retained for a minimum period of [period] following the date of the transaction, and for a maximum period of [period] following that date];

(e)    [communication data will be retained for a minimum period of [period] following the date of the communication in question, and for a maximum period of [period] following that date];

(f)    [usage data will be retained for [period] following the date of collection]; and

(g)    [[data category] will be retained for a minimum period of [period] following [date], and for a maximum period of [period] following [date]].

[additional list items]

7.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)    the period of retention of [personal data category] will be determined based on [specify criteria].

[additional list items]

7.5    Notwithstanding the other provisions of this Section 7, 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.

8.       Security of personal data

8.1    We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

8.2    We will store [your personal data] on [secure servers, personal computers and mobile devices, and in secure manual record-keeping systems].

8.3    The following personal data will be stored by us in encrypted form: [your name, contact information, password(s) and cardholder data].

8.4    Data[ relating to [your enquiries and financial transactions]] that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

8.5    You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8.6    You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

9.       Your rights

9.1    In this Section 9, we have listed the rights that you have under data protection law.

9.2    Your principal rights under data protection law are:

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

(b)    the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure - you can ask us to erase your personal data;

(d)    the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e)    the right to object to processing - you can object to the processing of your personal data;

(f)    the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

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

(h)    the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

9.3    These rights are subject to certain limitations and exceptions. 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/.

9.4    You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].

OR

9.       Your rights

9.1    In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

9.2    Your principal rights under data protection law are:

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

(b)    the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure - you can ask us to erase your personal data;

(d)    the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e)    the right to object to processing - you can object to the processing of your personal data;

(f)    the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

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

(h)    the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

9.3    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 can access [your personal data] by visiting [URL] when logged into our website.]

9.4    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.

9.5    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; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The 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].

9.6    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.

9.7    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 data 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.

9.8    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.

9.9    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.

9.10  To the extent that the legal basis for our processing of your personal data is:

(a)    consent; or

(b)    that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

        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.

9.11  If you consider that our processing of your personal data 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.

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

9.13  You may exercise any of your rights in relation to your personal data [by written notice to us] OR [by [methods]][, in addition to the other methods specified in this Section 9].

10.    Third party websites

10.1  Our website includes hyperlinks to, and details of, third party websites.

10.2  In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

11.    Personal data of children

11.1  Our [website and services are] targeted at persons over the age of [13] OR [16] OR [18] OR [[specify age]].

11.2  If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

12.    Updating information

12.1  Please let us know if the personal information that we hold about you needs to be corrected or updated.

13.    About cookies

13.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

13.2  Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

13.3  Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

14.    Cookies that we use

14.1  We use cookies for the following purposes:

(a)    [authentication and status - we use cookies [to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website][ (cookies used for this purpose are: [identify cookies])]];

(b)    [shopping cart - we use cookies to [maintain the state of your shopping cart as you navigate our website][ (cookies used for this purpose are: [identify cookies])]];

(c)    [personalisation - we use cookies [to store information about your preferences and to personalise our website for you][ (cookies used for this purpose are: [identify cookies])]];

(d)    [security - we use cookies [as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally][ (cookies used for this purpose are: [identify cookies])]];

(e)    [advertising - we use cookies [to help us to display advertisements that will be relevant to you][ (cookies used for this purpose are: [identify cookies])]];

(f)    [analysis - we use cookies [to help us to analyse the use and performance of our website and services][ (cookies used for this purpose are: [identify cookies])]]; and

(g)    [cookie consent - we use cookies [to store your preferences in relation to the use of cookies more generally][ (cookies used for this purpose are: [identify cookies])]].

[additional list items]

15.    Cookies used by our service providers

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

15.2  We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. 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.[ The relevant cookies are: [identify cookies].]

15.3  We publish Google AdSense advertisements on our website[, together with advertisements from the following advertisers and advertising networks that are distributed by Google: [identify and provide links to advertisers and networks]]. The advertisements may be personalised to reflect your interests. To help determine your interests Google and its partners use cookies.[ The relevant cookies served from our website are [identify cookies].] The cookies are used to track your previous visits to our website and your visits to other websites. You can opt out of Google's personalised advertising by visiting https://www.google.com/settings/ads and you can opt out of third party cookies use for personalised advertising by visiting http://www.aboutads.info. You can review Google's privacy policy at https://policies.google.com/privacy.

15.4  We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook's use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook's use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.

15.5  We use [identify service provider] to [specify service]. This service uses cookies for [specify purpose(s)]. You can view the privacy policy of this service provider at [URL].[ The relevant cookies are: [identify cookies].]

16.    Managing cookies

16.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

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

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

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

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

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

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

[additional list items]

16.2  Blocking all cookies will have a negative impact upon the usability of many websites.

16.3  If you block cookies, you will not be able to use all the features on our website.

17.    Cookie preferences

17.1  You can manage your preferences relating to the use of cookies on our website by visiting: [URL]

18.    Amendments

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

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

18.3  We [may] OR [will] notify you of [changes] OR [significant changes] to this policy [by email].

19.    Our details

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

19.2  We are registered in [England and Wales] under registration number [number], and our registered office is at [address].

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

19.4  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]

20.    Data protection registration

20.1  We are registered as a data controller with [the UK Information Commissioner's Office].

20.2  Our data protection registration number is [number].

21.    Representative within the European Union

21.1  Our representative within the European Union with respect to our obligations under data protection law is [identify representative] and you can contact our representative by [contact details].

22.    Data protection officer

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

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