1.1 We are committed to safeguarding the privacy of our clients.
1.2 This policy applies where we are acting as a data controller with respect to the personal data
of our clients; in other words, where we determine the purposes and means of the processing of
that personal data.
first visit our website.
1.4 In this policy, “we”, “us” and “our” refer to the owners of this website. For more information
about us, see Section 13.
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 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 Google Analytics. This usage data may be processed for the purposes of analyzing 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.
3.3 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 our legitimate interests, namely the proper
administration of our website and business.
3.4 We may process information that you post for publication on our website or through our
services (“publication data”). The publication data may b processed for the purposes of enabling
such publication and administering our website and services. The legal basis for this processing
is consent OR our legitimate interests, namely the proper administration of our website 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.
3.5 We may process information contained in any inquiry you submit to us regarding goods
and/or services (“inquiry data”). The inquiry 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
3.6 We may process information relating to our customer relationships, including customer
contact information (“customer relationship data”).[ The customer relationship data may include
your name, your employer, your job title or role, your contact details, and information contained in
communications between us and you. The source of the customer relationship data is you. The
customer relationship data may be processed for the purposes of managing our relationships
with customers, communicating with customers, keeping records of those communications and
promoting our products and services to customers. The legal basis for this processing is our
legitimate interests, namely the proper management of our customer relationships.
3.7 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, your card 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
business and services.
3.8 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.
3.9 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 interests, namely the proper administration of our
website and business and communications with users.
3.10 We may process any of your personal data identified in this policy where necessary for the
establishment, exercise or defense 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.
3.11 We may process any of your personal data identified in this policy where necessary for the
purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining
professional advice. The legal basis for this processing is our legitimate interests, namely the
proper protection of our business against risks.
3.12 In addition to the specific purposes for which we may process your personal data set out in
this Section 3, 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.
3.13 Please do not supply any other person’s personal data to us, unless we prompt you to do
4. Providing your personal data to others
4.1 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.
4.2 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, or the establishment, exercise or defense of legal
claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose your inquiry data to one or more of those selected third party suppliers of
goods and 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 inquiry data that we supply to it; and upon contacting
that third party’s use of your personal data.
4.4 In addition to the specific disclosures of personal data set out in this Section 4, 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 defense of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data
may be transferred to countries outside the European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in the United States of America. The
European Commission has 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
5.3 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.
6. Retaining and deleting personal data
6.1 This Section 6 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
6.2 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.
6.3 We will retain your personal data as follows:
(a) All personal data categories listed previously in this policy document will be retained for a
minimum period of 6 months and for a maximum period of 5 years.
6.4 Notwithstanding the other provisions of this Section 6, 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.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this
7.3 We may notify you of significant changes to this policy by email.
8. Your rights
8.1 In this Section 8, 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.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 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 contacting us through the website’s contact form.
8.4 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
8.5 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 defense of legal claims.
8.6 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 defense 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
defense of legal claims; for the protection of the rights of another natural or legal person; or for
reasons of important public interest.
8.7 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
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 defense of legal claims.
8.8 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.
8.9 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
8.10 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.
8.11 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
8.12 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
8.13 You may exercise any of your rights in relation to your personal data [ by written notice to
9. About cookies
9.1 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.
9.2 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.
9.3 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
10. Cookies that we use
navigate our website;
personalize the website for you;
accounts, including preventing fraudulent use of login credentials, and to protect our website and
11. Cookies used by our service providers
you visit our website.
11.2 We use Google Analytics to analyze the use of our website. Google Analytics gathers
information about website use by means of cookies. The information gathered relating to our
available at: https://www.google.com/policies/privacy/.[ The relevant cookies are: [identify
11.3 We publish Google AdSense interest-based advertisements on our website. These are
tailored by Google to reflect your interests. To determine your interests, Google will track your
behavior on our website and on other websites across the web using cookies. 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: ttp://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.[
The relevant cookies are: [identify cookies].]
12. Managing cookies
12.1 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?hl=en (Chrome);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 Please use the contact form on our website to:
– get in touch with our Data Protection Officer for any inquiries
– obtain details of any registered company
– request a copy of any information held about you