GDPR Policy Notice

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in section 6 below.

Under the GDPR, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data. This policy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in section 2.
• The right to access the personal data we hold about you. Section 11 will tell you how to do this.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in section 2 to find out more.
• The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in section 2 to find out more.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in section 2.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

We may collect some or all of the following personal data (this may vary according to your relationship with us)

• Name
• Job Title
• Business Name
• Business Address
• Email Address
• Telephone Number
• Website Address
• Systems supplied from us, and if necessary, access credentials

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:

• Providing and managing your account
• Supplying our products to you. Your personal details are required in order for us to enter into a contract with you
• Personalising and tailoring our products and services for you
• Providing technical support on the products and services supplied by us
• Communicating with you. This may include responding to emails or calls from you
• Supplying you with information by email or by post that you have opted-in to (you may unsubscribe or opt-out at any time)

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the policy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

We do not use automated systems for carrying out decision-making or profiling.

We will not share any of your personal data with any third parties for any purposes, subject to the one important exception.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in section 2.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 10 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

We may change this policy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be reflected in the policy statement freely available on our website.