This policy applies to all information we collect on our websites and through emails or other electronic communications between you and us.
Important information and who we are
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 has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
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.
Where we need to collect personal data and you fail to provide that data when requested, we may not be able to perform certain services for you. In this case, we may have to cancel a service you have requested from us and we may notify you if this is the case at the time.
We may use different methods to collect data from and about you including through:
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or mobile device if you agree. Cookies contain information that is transferred to your computer's or mobile device's hard drive.
We may use the following cookies:
We will only use your personal data when the law allows us to. Most commonly, we may use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we may obtain your consent before sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
We may use your personal data for a variety of reasons, both to provide services to you as user of our websites and otherwise.
Among other things, we may use your personal data to register you as a new user, to deliver and provide services to you, to collect and manage payments from you, to manage our relationship with you, to test and administer our websites, for data analysis to improve our websites, products and services, and to deliver relevant website and advertisement content to you.
For each use or your personal data, we will ensure that there is a legal basis for such use. Such bases include, among other things, our performance of services to you (fulfillment of a contract with you), our legitimate interests, and our compliance with legal obligations. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
You may receive marketing communications from us if you have requested information from us or purchased or services from us and you have not opted out of receiving that marketing.
We will use your personal data only 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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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 permitted by law.
We may share your personal data with the parties set out below:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our unaffiliated third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to 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 retain your personal data only for as long as reasonably necessary to fullfill 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.
In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Such rights may include the right to:
If you wish to exercise any of the rights set out above, please contact us.
California Civil Code Section § 1798.83 permits users of our websites that are California residents to request certain information regarding our disclosure of their personal to third parties for their direct marketing purposes. To make such a request, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may (a) charge a reasonable fee, or (b) refuse to comply with your request, if your request is clearly unfounded, repetitive, or excessive, to the extent permitted by law.
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.
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.