We are committed to safeguarding the privacy of our
website visitors and service users.
This policy applies where we are acting as a data
controller with respect to the personal data of our
website visitors and service users; in other words,
where we determine the purposes and means of the
processing of that personal data.
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.
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
publication of your information.
How we use your personal data
In this Section 2 we have set out:
the general categories of personal data that we
may process;
in the case of personal data that we did not
obtain directly from you, the source and
specific categories of that data;
the purposes for which we may process personal
data; and
the legal bases of the processing.
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. This usage data may be processed for the
purposes of analysing the use of the website and
services. The legal basis for this processing is our
legitimate interests, namely monitoring and improving
our website and services.
We may process your account data (“account
data”). The account data may include your
name and email address. The source of the account data
is you. The account data may be processed for the
purposes of operating our website, providing our
services, ensuring the security of our website and
services, maintaining back-ups of our databases and
communicating with you. The legal basis for this
processing is consent.
We may process your personal data that are provided in
the course of the use of our services (“service
data”). The service data may be processed
for the purposes of operating our website, providing our
services, ensuring the security of our website and
services, maintaining back-ups of our databases and
communicating with you. The legal basis for this
processing is the performance of a contract between you
and us and/or taking steps, at your request, to enter
into such a contract.
We may process information contained in any enquiry you
submit to us regarding goods and/or services
(“enquiry data”). The enquiry data may
be processed for the purposes of offering, marketing and
selling relevant goods and/or services to you. The legal
basis for this processing is consent.
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, and the
transaction details. The transaction data may be
processed for the purpose of supplying the purchased
goods and 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/or
taking steps, at your request, to enter into such a
contract and our legitimate interests, namely the proper
administration of our website and business.
We may process information that you 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.
We may process information contained in or relating to
any communication that you send to us
(“correspondence data”). The
correspondence data may include contact details. 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 interests,
namely the proper administration of our website and
business and communications with users.
We may process any of your personal data identified in
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 2, we
may also process any of 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.
Please do not supply any other person’s personal data to
us, unless we prompt you to do so.
Providing your personal data to others
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.
We may disclose personal data to our suppliers or
subcontractors insofar as reasonably necessary for us to
carry out the duties we are instructed to undertake,
including the selling/or buying and/or letting/renting
of property.
Financial transactions relating to services may be
handled by our payment services providers, Go Cardless.
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 gocardless.co.uk
We may disclose your enquiry data to one or more of
those selected third party suppliers of goods and
services outlined below 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
enquiry 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.
In addition to the specific disclosures of personal data
set out in this Section 3, 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.
Retaining and deleting personal data
This Section 4 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 your personal data as follows:
Names, address, telephone numbers and email
address will be retained until you inform us
that you no longer wish this data to be held.
Notwithstanding the other provisions of this Section 4,
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.
Security of personal data
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.
We will store all your personal data on secure servers,
personal computers and mobile devices, and in secure
manual record-keeping systems.
The following personal data will be stored by us in
encrypted form: your name, contact information,
password(s) and cardholder data.
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.
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.
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).
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.
Your rights
In this Section 7, 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.
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; 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.
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.
To the extent that the legal basis for our processing of
your personal data is:
consent; or
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.
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.
Third party websites
Our website includes hyperlinks to, and details of,
third party websites such as Job Boards.
We have no control over, and are not responsible for,
the privacy policies and practices of third parties.
Personal data of children
Our website and services are targeted at persons over
the age of 18.
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.
Updating information
Please let us know if the personal information that we
hold about you needs to be corrected or updated.
About cookies
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.
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.
Cookies do not typically contain any information that
personally identifies a user, but personal information
that we store about you may be linked to the information
stored in and obtained from cookies.
Cookies that we use
We use cookies for the following purposes:
analysis – we use cookies to help us to analyse
the use and performance of our website and
services.
Cookies used by our service providers
Our service providers use cookies and those
cookies may be stored on your computer when you
visit our website.
We use Google Analytics to analyse the use of
our website. Google Analytics gathers
information about website use by means of
cookies. The information gathered relating to
our website is used to create reports about the
use of our website. Google’s privacy policy is
available at: https://www.google.com/policies/privacy/.
We publish Google AdSense advertisements on our website.
To determine your interests, Google will track your
behaviour on our website and on other websites across
the web using cookies. This behaviour tracking allows
Google to tailor the advertisements that you see on
other websites to reflect your interests (but we do not
publish interest-based advertisements on our website).
You can view, delete or add interest categories
associated with your browser by visiting: https://adssettings.google.com.You
can also opt out of the AdSense partner network cookie
using those settings or using the Network Advertising
Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However,
these opt-out mechanisms themselves use cookies, and if
you clear the cookies from your browser your opt-out
will not be maintained. To ensure that an opt-out is
maintained in respect of a particular browser, you may
wish to consider using the Google browser plug-ins
available at: https://support.google.com/ads/answer/7395996.
We use Melbourne to manage our web and database servers.
You can view the privacy policy of this service provider
at melbourne.co.uk
Managing cookies
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:
