Full name of manager: Joel Teague
Email address: [email protected]
Postal address: Science Park Centre 6 Babbage Way, Clyst Honiton, Exeter, England, EX5 2FN
Telephone number: 01392 240840 / 07943 365183
1.5. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
3. THE DATA WE COLLECT ABOUT YOU
4. HOW IS YOUR PERSONAL DATA IS COLLECTED?
5. HOW WE USE YOUR PERSONAL DATA
8. DISCLOSURES OF YOUR PERSONAL DATA
10. DATA SECURITY
11. DATA RETENTION
2. IMPORTANT INFORMATION
2.2. This website is not intended for children and we do not knowingly collect data relating to children.
2.5. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
3. THE DATA WE COLLECT ABOUT YOU
3.1. 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) or data about corporate entities, like a company.
3.2. We may collect, use, store and transfer different kinds of personal data about you which we include below as follows:
- a) First name and last name
- b) Email address
- c) Post code
- d) Telephone number
- e) Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- f) Usage Data includes information about how you use our website
- g) Marketing and Communications Data includes emails, document views, email link clicks and opens, and your preferences in receiving marketing from us and our third parties and your communication preferences.
3.3. Aggregated Data. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
3.4. Special Categories. 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 offences.
3.5. Data not provided. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the website services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
4. HOW IS YOUR PERSONAL DATA COLLECTED?
4.1. We use different methods to collect data from and about you including through:
- a) Direct interactions. You may give us your first name and last name, email address, post code, and telephone number by filling in forms or by corresponding with us by webchat, post, phone, email or otherwise. This includes personal data you provide when you:
- I. Make an enquiry by filling out the contact form on our website;
- II. subscribe to our publications;
- III. request marketing to be sent to you;
- IV. enter a competition, promotion or survey; or
- V. give us feedback or contact us.
- b) Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section titled ‘cookies’ under ‘HOW WE USE YOUR PERSONAL DATA’ for further details.
- c) Third parties or publicly available sources. We will receive Technical Data from analytics providers, such as Google based outside the EU;
5. HOW WE USE YOUR PERSONAL DATA
5.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where we need to perform the contract we are about to enter into or have entered into with you, where it is necessary for our legitimate interests (or those of a third party) or where we need to comply with a legal obligation. The meaning of Lawful Basis is further defined in the glossary.
5.2. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
5.3. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
|(a) first name and last name, email address, post code, and telephone number
(b) Marketing and Communications
|(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) first name and last name, email address, post code, and telephone number
(c) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) first name and last name, email address, post code, and telephone number
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) first name and last name, email address, post code, and telephone number
(c) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) first name and last name, email address, post code, and telephone number
(d) Marketing and Communications
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
5.4. 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.
6.1. 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:
- a) Promotional offers from us. We may use your Identity, first name and last name, email address, post code, and telephone number, 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 through our third party provider Mailchimp if you have requested information from us and you have not opted out of receiving that marketing.
- b) Third-party marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
- c) 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 purchases or other transactions.
7.2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. We use the following cookies:
- a) Strictly necessary cookies. These are cookies that are required for the operation of our website.
- b) Analytical, tracking or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way website works, for example, by ensuring that users are finding what they are looking for easily. We use Google Analytics, which registers a unique ID that is used to generate statistical data on how you use our website when you visit.
- c) Targeted cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests: We use YouTube, which registers a unique ID to keep statistics of what videos from YouTube you have seen and stores your video player preferences using embedded YouTube video. We also use Facebook Pixel and Facebook First-party cookies. We share data from our website’s first-party cookies with Facebook. This helps us deliver Facebook relevant ads to people who may be interested in our products or services.
7.4. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
8. DISCLOSURES OF YOUR PERSONAL DATA
8.1. We may share your personal data with the parties set out below for the purposes set out in the table ‘Purposes for which we will use your personal data’ above:
- a) External Third Parties as set out in the Glossary;
- b) Specific third parties listed in the ‘Cookies section’;
8.2. 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 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.
9. INTERNATIONAL TRANSFERS
9.1. Your personal data may be stored or transferred to countries outside the EEA for the purposes described in this policy and pursuant to providing the services to you. When we store or transfer your personal data outside the EEA, we will do so in accordance with applicable law and we will ensure a similar degree of protection is afforded to it by implementing the appropriate safeguards listed below. Transfers of personal data will only be made:
- a) to a country recognised by the European Commission as providing an adequate level of protection; or
- b) to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the UK GDPR or by implementing other appropriate cross-border transfer solutions to provide adequate protection. By using visiting our website, you understand that your personal data may be transferred to our facilities and those third parties with whom we share it as described in this policy.
10. DATA SECURITY
10.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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.
10.2. 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.
11. DATA RETENTION
11.1. We will only retain your personal data for as long as reasonably necessary to fulfil 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.
11.2. 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 unauthorised 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.
11.3. By law we must keep basic information about our customers (including first name and last name, email address, post code, and telephone number, and Transaction Data) for six years after they cease being customers for tax purposes.
12. YOUR LEGAL RIGHTS
12.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data as follows (please check the Glossary for further information on each right):
- a) Request access to your personal data.
- b) Request correction of your personal data.
- c) Request erasure of your personal data.
- d) Object to processing of your personal data.
- e) Request restriction of processing your personal data.
- f) Request transfer of your personal data.
- g) Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
12.2. Fees. 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.
12.3. Specific Information. 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.
12.4. Response time. 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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service or 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.
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time 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.
In addition to any third parties specifically mentioned throughout this document, External Third Parties can be summarised as follows:
- a) Service providers acting as processors based in the US, such as Google, Facebook, and Mailchimp who provide IT and system administration services.
- b) Service providers acting as processors based in the UK who provide IT and system administration services.
- c) Professional advisers, acting as processors, including lawyers, bankers, auditors and insurers based in the UK, who provide consultancy, banking, legal, insurance and accounting services.
- d) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
- a) 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.
- b) 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.
- c) 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.
- d) 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.
- e) 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:
- i. if you want us to establish the data’s accuracy;
- ii. where our use of the data is unlawful but you do not want us to erase it;
- iii. 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; or
- iv. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- f) 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.
- g) 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.