PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think

you may want or need, or what may be of interest to you. This is how we decide which products,

services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or

purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for

marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the

opt-out links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided

to us as a result of a product or service purchases

COOKIES

This Website utilizes industry standard analytics packages which gather limited information on visitors

to our Website automatically and stores this anonymous information in server log files. This information

may include IP addresses, browser type, basic IP information, referring pages, operating system used

and date/time stamps. This information does not identify individual users; it is used only for site

administration, as well as for analysis of website usage and trends.

Additionally, cookies may be used to provide easier and faster access to website features such as logins

and/or repeat visits. Cookies are very small text files that are stored on personal computers for reference purposes. We do not store in cookies to any personally identifiable information in cookies.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or

access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

CHANGE OF PURPOSE

We will only use your personal data 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.

DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table

above.

• External Third Parties as set out in the Glossary.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to

our business, then the new owners may use your personal data in the same way as set out in this

privacy policy.

DATA SECURITY

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 only retain your personal data for as long as reasonably necessary to fulfill 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 you can ask us to delete your data: see your legal rights below for further

information.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal

data

You may have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This

enables you to receive a copy of the personal data we hold about you and to check that we are

lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any

incomplete or inaccurate data we hold about you corrected, though we may need to verify the

accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data

where there is no good reason for us continuing to process it.

You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of

a third party) and there is something about your particular situation which makes you want to object

to processing on this ground as you feel it impacts on your fundamental rights and freedoms.

You also have the right to object where we are processing your personal data for direct marketing

purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process

your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the

processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.

• Where our use of the data is unlawful but you do not want us to erase it.

• Where you need us to hold the data even if we no longer require it as you need it to establish,

exercise or defend legal claims.

• You have objected to our use of your data but we need to verify whether we have overriding

legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a

third party you have chosen, your personal data in a structured, commonly used, machine-readable

format. Note that this right only applies to automated information which you initially provided

consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data.

However, this will not affect the lawfulness of any processing carried out before you withdraw your

consent. If you withdraw your consent, we may not be able to provide certain products or services to

you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above and you believe you have the right to do so, please

contact us.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

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.

TIME LIMIT TO RESPOND

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.

GLOSSARY

Legitimate Interest means the interest of our business in conducting and managing our business to

enable us to give you the best service/product and the best and most secure experience. We make sure

we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests

We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a

contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for

compliance with a legal obligation that we are subject to. 

External third parties means:

• Service providers who provide IT and system administration services.

• Professional advisers including lawyers, bankers, auditors and insurers based in who provide

consultancy, banking, legal, insurance and accounting services.