Your Privacy
Our Website adheres to all legal requirements to protectyour privacy. This Privacy Policy is a legal statement that explains when,where, why and how we collect, use and store your personal data when you view,use or interact with our website. This Privacy Policy is effective from 22nd May 2018.
Definitions
You will see terms in our Privacy Policy that arecapitalized. These terms have meanings as described in the definitions sectionbelow.
Personal Data: Any information regarding a natural person,a legal person, an institution or an association, which is, or can be,identified, even indirectly, by reference to any other information, including apersonal identification number.
Usage Data: Information collected automatically from thiswebsite (or third-party services employed in this website), which can include:the IP addresses or domain names of the computers utilised by the Users who usethis website, the URI addresses (Uniform Resource Identifier), the time of therequest, the method utilised to submit the request to the server, the size ofthe file received in response, the numerical code indicating the status of theserver’s answer (successful outcome, error, etc.), the country of origin, thefeatures of the browser and the operating system utilised by the User, thevarious time details per visit (e.g. the time spent on each page within thewebsite) and the details about the path followed within the website withspecial reference to the sequence of pages visited, and other parameters aboutthe device operating system and/or the User’s IT environment.
User: The User is the individual using our Service. TheUser corresponds to the Data Subject, who is the subject of Personal Data.
Data Controller: Data Controller means a natural or legalperson who (either alone or jointly or in common with other persons) determinesthe purposes for which and the manner in which any personal data are, or are tobe, processed. For the purpose of this Privacy Policy, we are a Data Controllerof your data.
Data Processors (or Service Providers):
Data Processor (or Service Provider) means any natural orlegal person who processes the data on behalf of the Data Controller. We mayuse the services of various Service Providers in order to process your datamore effectively. Data Subject: Data Subject is any living individual who isthe subject of Personal Data.
GDPR: General Data Protection Regulation Data ProtectionDirective. The current legislation - (EU) 2016/679 is a regulation in EU law ondata protection and privacy for all individuals within the European Union. Itaddresses the export of personal data outside the EU.
Website: The hardware or software tool by which thePersonal Data of the User is collected.
Cookies: Cookies are small pieces of data stored on aUser’s device.
Table of Contents
Summary
Our data controller contact details
Information collected: Website visit
Information collected: Contact us
Information collected: Website interaction
Information collected: Place order
Information collected: Third parties
Profiling
Displaying content from external platforms
Platform services
Disclosure and additional uses of your information
Data retention: Personal data
Data security: Personal data
Data Transfers outside the European Economic Area
GDPR Individual rights
The right to restrict processing
Sensitive Personal Information
Privacy Policy Updates
External Links
Children’s Data Privacy Compliance
DNT (Do Not Track) Disclosure: The California Online PrivacyProtection Act
How to contact us
Your right to complain
1. Summary
This section summarises as a general overview how we obtain,store and use information about you.
Data Controller:
Ian Ayliffe, Data Protection Lead, Promote-UK Ltd, 4 OldPark Lane, Mayfair, London, W1K 1QW.
How we collect or obtain information about you:
• when you provide it to us (e.g. by contacting us, placingan order on our website, booking an appointment, using our chat system,browsing our products or by signing up to your e-newsletter).
• from your use of our website, using cookies andoccasionally from third parties.
Information we collect:
Name, contact details, payment information e.g. your creditor debit card details, usage data including IP address, information fromcookies, information about your computer or device (e.g. device and browsertype), information about how you use our website (e.g. which pages you haveviewed, the time when you view them and what you clicked on, the geographicallocation from which you accessed our website (based on your IP address),company name or business name (if applicable), VAT number (if applicable).
How we use your information:
• For administrative and business purposes (particularly tocontact you and process orders you place on our website), to improve ourbusiness and website, to fulfil our contractual obligations, to advertise our goodsand services, to analyse your use of our website, and in connection with ourlegal rights and obligations;
• To notify you about changes to our business, products andservices;
• To provide customer support;
• To gather analysis or valuable information so that we canimprove our Web Service and products;
• To monitor the usage of our website;
• To detect, prevent and address technical issues;
• To provide you with news, offers and general informationabout other goods, services and events which we offer that are similar to thosethat you have already purchased or enquired about unless you have opted not toreceive such information. You have the legal right to opt-in and opt-out.Opt-out is the default value in accordance to the GDPR.
Disclosure of your information to third parties:
Only to the extent necessary to run our business, to ourservice providers, to fulfil any contracts we enter into with you, whererequired by law or to enforce our legal rights:
• Business Transaction. If we are involved in a merger,acquisition or asset sale, your Personal Data may be transferred. We willprovide notice before your Personal Data is transferred and becomes subject toa different Privacy Policy.
• Disclosure for Law Enforcement. Under certaincircumstances, we may be required to disclose your Personal Data if required todo so by law or in response to valid requests by public authorities (e.g. acourt or a government agency).
Do we sell your information to third parties (other than inthe course of a business sale or purchase or similar event):
No
Are there consequences in not supplying your personal data:
To place an order with us we will require email address,billing address, shipping address, company name (if applicable), & VATnumber (if applicable). Usage data to place an order is not mandatory.You caninstruct your browser to refuse all cookies or to indicate when a cookie isbeing sent.
How long we retain your information:
For no longer than necessary, taking into account any legalobligations we have (e.g. to maintain records for tax purposes), any otherlegal basis we have for using your information (e.g. your consent, performanceof a contract with you or our legitimate interests as a business) and certainadditional factors described in the main section below entitled How long weretain your information. For specific retention periods in relation to certaininformation which we collect from you, please see the main section belowentitled How long we retain your information.
How we secure your information:
Using appropriate technical and organisational measuressuch as storing your information on secure servers, encrypting transfers ofdata to or from our servers using Secure Sockets Layer (SSL) technology,encrypting payments you make on or via our website using Secure Sockets Layer(SSL) technology, only granting access to your information where necessary.This site uses a COMODO CA Limited to offer secure communications by encryptingall data to and from the site.
Use of cookies:
We use cookies on our website including essential,functional, analytical and targeting cookies. You can instruct your browser torefuse all cookies or to indicate when a cookie is being sent.
Like most sites, we use cookies for several reasons, the mainreasons being:
• Analytics & Tracking – we use cookies to understandhow the site is being used in order to improve the user experience. User datais anonymous. For more information, please visit our cookies policy.
Transfers of your information outside the European EconomicArea:
We will only transfer your information outside the EuropeanEconomic Area if we are required to do so by law.
Profiling and automated decision-making:
Profiling is used to help promote our blog posts orproducts through social media paid adverts, web analytics and cookies. We donot make decisions by automated means.
GDPR Individual rights:
• to access your information and to receive informationabout its use;
• to have your information corrected and/or completed;
• to have your information deleted;to restrict the use ofyour information;
• to receive your information in a portable format;
• to object to the use of your information;to withdraw yourconsent to the use of your information;
• not to have significant decisions made about you basedsolely on automated processing of your information, including profiling;
• to complain to a supervisory authority.
Sensitive personal information:
We do not knowingly or intentionally collect what iscommonly referred to as ‘sensitive personal information’. Please do not submitsensitive personal information about you to us. For more information, pleasesee the main section below entitled Sensitive Personal Information.
Legal Basis for Processing Personal Data Under General DataProtection Regulation (GDPR):
If you are from the European Economic Area (EEA), our legalbasis for collecting and using the personal information described in thisPrivacy Policy depends on the Personal Data we collect and the specific contextin which we collect it.
We may process your Personal Data because:
• We need to perform a contract with you;
• You have given us permission to do so;
• The processing is in our legitimate interests and it’s notoverridden by your rights;
• For payment processing purposes;
• To comply with the law.
2. Our data controller contact details
The data controller in respect of our website is IanAyliffe, (DPO) of Promote-UK Ltd, 4 OldPark Lane, Mayfair, London, W1K 1QW. You can contact the data controller bywriting to the business address above or sending an email toprivacy@promoteukltd.com
If you have any questions about this Privacy Policy, pleasecontact the data controller.
3. Information collected: Website visit
Web server log information:
We use a third party server to host our website calledWebhosting UK COM Ltd, the privacy policy of which is available here.
Our website server automatically logs the IP address you useto access our website as well as other information about your visit such as thepages accessed, information requested, the date and time of the request, thesource of your access to our website (e.g. the website or URL (link) whichreferred you to our website), and your browser version and operating system.
Our server is located in the UK (European Economic Area).
Use of website server log information for IT securitypurposes:
Webhosting UK COM Ltd collect and store server logs toensure network and IT security and so that the server and website remainuncompromised. This includes analysing log files to help identify and preventunauthorised access to our network, the distribution of malicious code, denialof services attacks and other cyber attacks, by detecting unusual or suspiciousactivity. Unless we are investigating suspicious or potential criminalactivity, we do not make, nor do we allow our hosting provider to make, anyattempt to identify you from the information collected via server logs.
Legal basis for processing:
Compliance with a legal obligation to which we are subject(Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation:
We have a legal obligation to implement appropriatetechnical and organisational measures to ensure a level of security appropriateto the risk of our processing of information about individuals. Recordingaccess to our website using server log files is such a measure.
Legal basis for processing:
Our and Webhosting UK COM Ltd legitimate interests (Article6(1)(f) of the General Data Protection Regulation).
Legitimate interests:
We and our third party hosting provider Webhosting UK COMLtd have a legitimate interest in using your information for the purposes ofensuring network and information security.
Use of website server log information to analyse websiteuse and improve our website:
We use the information collected by our website server logsto analyse how our website users interact with our website and its features forwebsite performance reasons.
Legal basis for processing:
Our legitimate interests (Article 6(1)(f) of the GeneralData Protection Regulation).
Legitimate interest:
Improving our website for our website users and getting toknow our website users’ preferences so our website can better meet their needsand desires.
Cookies:
Cookies are data files which are sent from a website to abrowser to record information about users for various purposes. We use cookieson our website, including essential, functional, analytical and targetingcookies. For further information on how we use cookies, please see our cookiespolicy. You can reject some or all of the cookies we use on or via our websiteby changing your browser settings or non-essential cookies but doing so canimpair your ability to use our website or some or all of its features. Forfurther information about cookies, including how to change your browsersettings, please visit www.allaboutcookies.org or see our Cookies Policy.
Analytics & Tracking:
We use cookies to understand how the site is being used inorder to improve the user experience. User data is anonymous.
4. Informationcollected: Contact us
Email:
When you send an email to the email address displayed onour website we collect your email address and any other information you providein that email (such as your name, telephone number and the informationcontained in any signature block in your email).
Legal basis for processing:
Our legitimate interests (Article 6(1)(f) of the GeneralData Protection Regulation).
Legitimate interest(s):
Responding to enquiries and messages we receive and keepingrecords of correspondence.
Legal basis for processing:
Necessary to perform a contract or to take steps at yourrequest to enter into a contract (Article 6(1)(b) of the General DataProtection Regulation).
Reason why necessary to perform a contract:
Where your message relates to us providing you with goodsor services or taking steps at your request prior to providing you with ourgoods and services (for example, providing you with information about suchgoods and services), we will process your information in order to do so.
Transfer and storage of your information:
We use a third party email provider to store emails yousend us. Our third party email provider is either one or a combination ofGoogle Mail. Their privacy policy is available here. Email by Microsoft. Theirprivacy policy is here. Webhosting UKCOM Ltd and their privacy policy is here. Emails you send us will be storedwithin the European Economic Area on Google’s servers in Belgium. For furtherinformation please see the section of this privacy policy entitled DataTransfers outside the European Economic Area. Microsoft is in Ireland andWebhosting UK COM Ltd email is in the UK.
Contact form:
When you contact us using our contact form, we collectmandatory information including your name, email address and IP address.
Legal basis for processing:
Our legitimate interests (Article 6(1)(f) of the GeneralData Protection Regulation).
Legitimate interest(s):
Responding to enquiries and messages we receive and keepingrecords of correspondence.
Legal basis for processing:
Necessary to perform a contract or to take steps at yourrequest to enter into a contract (Article 6(1)(b) of the General DataProtection Regulation).
Reason why necessary to perform a contract:
Where your message relates to us providing you with goodsor services or taking steps at your request prior to providing you with ourgoods and services (for example, providing you with information about suchgoods and services), we will process your information in order to do so.
Transfer and storage of your information:
Messages you send us via our contact form will be storedwithin the European Economic Area on Webhosting UK COM Ltd servers in the UK. For information about the safeguardsused when your information is transferred outside the European Economic Area,see the section of this privacy policy below entitled Data Transfers outsidethe European Economic Area.
Phone:
When you contact us by phone, we collect your phone numberand any information provide to us during your conversation with us. We do notrecord phone calls.
Legal basis for processing:
Our legitimate interests (Article 6(1)(f) of the GeneralData Protection Regulation).
Legitimate interest(s):
Responding to enquiries and messages we receive and keepingrecords of correspondence.
Legal basis for processing:
Necessary to perform a contract or to take steps at yourrequest to enter into a contract (Article 6(1)(b) of the General DataProtection Regulation).
Reason why necessary to perform a contract:
Where your message relates to us providing you with goodsor services or taking steps at your request prior to providing you with ourgoods and services (for example, providing you with information about suchgoods and services), we will process your information in order to do so.
Transfer and storage of your information:
Information about your call, such as your phone number andthe date and time of your call, is processed by our third party telephoneservice provider which is located in the UK. Information about your phone callwill be stored by our third party telephone service provider within the UK (European Economic Area).
Post:
If you contact us by post, we will collect any informationyou provide to us in any postal communications you send us.
Legal basis for processing:
Our legitimate interests (Article 6 (1) (f) of the GeneralData Protection Regulation).
Legitimate interest(s):
Responding to enquiries and messages we receive and keepingrecords of correspondence.
Legal basis for processing:
Necessary to perform a contract or to take steps at yourrequest to enter into a contract (Article 6(1)(b) of the General DataProtection Regulation).
Reason why necessary to perform a contract:
Where your message relates to us providing you with goodsor services or taking steps at your request prior to providing you with ourgoods and services (for example, providing you with information about suchgoods and services), we will process your information in order to do so).
5. Information collected: Website interaction
Registering on our website:
When you register and create an account on our website, wecollect the following information:
• Information about your computer and about your visits toand use of this website, such as your IP address, geographical location,browser type, referral source, length of visit and number of page views;
• Information relating to any transactions carried outbetween you and us on or in relation to this website, including informationrelating to any purchases you make of our goods or services (including name,e-mail address, postal address and phone number).
• Information that you provide to us for the purpose ofsubscribing to our e-mail notifications, placing reviews on our website,booking an appointment and when using our chat service.
If you do not provide the mandatory information required bythe registration form, you will not be able to register or create an account onour website.
Legal basis for processing:
Necessary to perform a contract(Article 6(1)(b) of theGeneral Data Protection Regulation).
Reason why necessary to perform a contract:
Creating an account on our website is necessary to allowyou to access the goods and services you have purchased from us.
Transfer and storage of your information:
Information you submit to us via the registration form onour website will be stored within the UK (European Economic Area) on WebhostingUK COM Ltd. Our web server is located in the UK. For more context, you canreview Webhosting UK COM Ltd Privacy Policy.
6. Information collected: Online Booking
Mandatory information:
When you place an order for goods or services on ourwebsite, we collect your name, email address, billing address, shippingaddress, company name (if applicable), & VAT number (if applicable). If youdo not provide this information, you will not be able to purchase goods orservices from us on our website or enter into a contract with us.
Legal basis for processing:
Necessary to perform a contract (Article 6(1)(b) of theGeneral Data Protection Regulation).
Reason why necessary to perform a contract:
We need the mandatory information collected by our checkoutform or via email to establish who the contract is with and to contact you tofulfil our obligations under the contract, including sending you receipts andorder confirmations.
Legal basis for processing:
Compliance with a legal obligation (Article 6(1)(c) of theGeneral Data Protection Regulation).
Legal obligation:
We have a legal obligation to issue you with an invoice forthe goods and services you purchase from us where you are VAT registered and werequire the mandatory information collected by our checkout form for thispurpose. We also have a legal obligation to keep accounting records, includingrecords of transactions.
Optional information:
We also collect optional information from you, such as yourphone number and information about how you heard about us.
7. Information collected: Third parties
Generally, we do not receive information about you from thirdparties.
It is also possible that third parties with whom we have hadno prior contact may provide us with information about you.
Information we obtain from third parties will generally beyour name and contact details, but will include any additional informationabout you which they provide to us. In certain circumstances (for example, toverify the information we hold about you or obtain missing information werequire to provide you with a service) we will obtain information about youfrom certain publicly accessible sources, both EU and non-EU, such as onlinecustomer databases, business directories, media publications, social media, andwebsites (including your own website if you have one).
Legal basis for processing:
Necessary to perform a contract or to take steps at yourrequest to enter into a contract (Article 6(1)(b) of the General DataProtection Regulation).
Reason why necessary to perform a contract:
Where a third party has passed on information about you tous (such as your name and email address) in order for us to provide services toyou, we will process your information in order to take steps at your request toenter into a contract with you and perform a contract with you. We will alsoobtain information about you from public sources in order to enable us tounderstand your business and provide services to you.
Legal basis for processing:
Consent (Article 6(1)(a) of the General Data ProtectionRegulation).
Consent:
Where you have asked that a third party to shareinformation about you with us and the purpose of sharing that information isnot related to the performance of a contract or services by us to you.
Legal basis for processing:
Our legitimate interests (Article 6(1)(f) of the GeneralData Protection Regulation).
Legitimate interests:
Where a third party has shared information about you withus and you have not consented to the sharing of that information, we will havea legitimate interest in processing that information in certain circumstances.we will have a legitimate interest in obtaining information about you frompublic and private sources in order to investigate and pursue any potential infringement.
8. Profiling
Profiling is any form of automated processing of yourinformation to evaluate personal aspects about you, in particular to analyse orpredict things like your performance at work, economic situation, health,personal preferences, interests, reliability, behaviour, location or movements.
Use of profiling for web analytics:
Our web analytics service, Google Analytics collectsinformation such as your location (based on your IP address) and your behaviour(based on cookies) when you access our website (such as the pages you visit andwhat you click on). We will only process information from cookies if you haveconsented to us setting cookies on your computer in accordance with our CookiesPolicy.
Logic involved:
By automatically analysing and categorising informationsuch as the location (based on IP address) as well as the behaviour and devicesof visitors to our website (using cookies), we are able to gain a betterunderstanding of what our website visitors want (in terms of the content of ourwebsite and our products), how to improve our website and how to advertise andmarket our services to them.
Reason:
Cookies will be used to track and store information aboutyour behaviour and device on our website (unless you have opted out fromreceiving such cookies by following this guide) and your location will beanalysed based on your IP address. We may target advertisements based on thelevel of interest we receive from certain visitors and their behaviour on ourwebsite.
9. Displaying content from external platforms
This type of service allows you to view content hosted onexternal platforms directly from the pages of this Website and interact withthem. This type of service might still collect web traffic data for the pageswhere the service is installed, even when users do not use it.
Typekit (Adobe Systems):
Typekit is an online service which offers a subscriptionlibrary of high-quality fonts. The fonts may be used directly on websites orsynced via Adobe Creative Cloud to applications on the subscriber's computers.Personal Data collected: Usage Data and various types of Data as specified inthe privacy policy of the service. Place of processing: US – Privacy Policy.
YouTube video widget (Google Inc.):
YouTube is a video content visualisation service provided byGoogle Inc. that allows this Website to incorporate content of this kind on itspages.Personal Data collected: Cookies and Usage Data. Place of processing: US– Privacy Policy.
YouTube button and social widgets (Google Inc.):
The YouTube button and social widgets are services allowinginteraction with the YouTube social network provided by Google Inc.PersonalData collected: Cookies and Usage Data. Place of processing: US – PrivacyPolicy.
Instagram widget (Instagram, Inc.)
Instagram is an image visualization service provided byInstagram, Inc. that allows this Application to incorporate content of thiskind on its pages. Personal Data collected: Cookies and Usage Data. Place ofprocessing: US – Privacy Policy
Pinterest and socialwidgets (Pinterest Europe Ltd)
Pinterest is a web and mobile application company thatoperates a software system designed to discover information online. PersonalData collected: Cookies and Usage Data. Place of processing: Ireland – PrivacyPolicy
Facebook Like button and social widgets (Facebook, Inc.):
The Facebook Like button and social widgets are servicesallowing interaction with the Facebook social network provided by Facebook,Inc. Personal Data collected: Cookies and Usage Data. Place of processing: US –Privacy Policy.
Twitter Tweet button and social widgets (Twitter, Inc.):
The Twitter Tweet button and social widgets are servicesallowing interaction with the Twitter social network provided by Twitter, Inc.Personal Data collected: Cookies and Usage Data: Place of processing: US –Privacy Policy.
LinkedIn button and social widgets (LinkedIn Corporation):
The LinkedIn button and social widgets are servicesallowing interaction with the LinkedIn social network provided by LinkedInCorporation. Personal Data collected: Cookies and Usage Data. Place ofprocessing: US – Privacy Policy.
Flickr button and social widgets (SmugMug, Inc.):
The Flickr button and social widgets are services allowinginteraction with the Flicr image sharing social network provided by LinkedInSmugMug, Inc.. Personal Data collected: Cookies and Usage Data. Place ofprocessing: US – Privacy Policy.
Google+ +1 button and social widgets (Google Inc.):
The Google+ +1 button and social widgets are servicesallowing interaction with the Google+ social network provided by Google Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy.
Google Maps widget (Google Inc.) Google Maps is a mapsvisualization service provided by Google Inc. that allows this Website toincorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US – Privacy Policy
10. Platform services
These services have the purpose of hosting and running keycomponents of this Website, therefore allowing the provision of this Websitefrom within a unified platform. Such platforms provide a wide range of tools tothe Owner – e.g. analytics, user registration, commenting, database management,e-commerce, payment processing – that imply the collection and handling ofPersonal Data. Some of these services work through geographically distributedservers, making it difficult to determine the actual location where thePersonal Data are stored.
WordPress.com (Automattic Inc.):
WordPress.com is a platform provided by Automattic Inc.that allows the owner to build, run and host this Website.
Personal Data collected: various types of Data as specifiedin the privacy policy of the service.
Place of processing: USA – Privacy Policy.
Your information will be shared with these service providerswhere necessary to provide you with the service you have requested, whetherthat is accessing our website or ordering goods and services from us.
Legal basis for processing:
Legitimate interests (Article 6(1)(f) of the General DataProtection Regulation).
Google Inc:
Google collects information through our use of GoogleAnalytics on our website. Google uses this information, including IP addressesand information from cookies, for a number of purposes, such as improving itsGoogle Analytics service. Information is shared with Google on an aggregatedand anonymised basis. To find out more about what information Google collects,how it uses this information and how to control the information sent to Google,please see the following page:https://www.google.com/policies/privacy/partners/
Legal basis for processing:
Our legitimate interests (Article 6(1)(f) of the GeneralData Protection Regulation).
Legitimate interest(s):
Meeting our contractual obligations to Google under ourGoogle Analytics Terms of Service(https://www.google.com/analytics/terms/us.html) You can opt out of GoogleAnalytics by installing the browser plugin here:https://tools.google.com/dlpage/gaoptout
Transfer and storage of your information:
Information collected by Google Analytics is stored outsidethe European Economic Area on Google’s servers in the United States ofAmerica.For further information, See the section of this privacy policy belowentitled Data Transfers outside the European Economic Area
Legal basis for processing:
Our legitimate interests (Article 6(1)(f) of the GeneralData Protection Regulation).
Legitimate interest:
Running and managing our business efficiently.
11. Disclosure and additional uses of your information
Insurers:
Information is shared with our insurers upon anofficial claim against us
Legal basis for processing:
Our legitimate interests (Article 6(1)(f) of the GeneralData Protection Regulation).
Legitimate interest:
Running and managing our business effectively. Disclosureand use of your information for legal reasons: Indicating possible criminalacts or threats to public security to a competent authority, such as thePolice.In connection with a legal or potential legal dispute or proceedings toresolve the dispute.For ongoing compliance with laws, regulations and otherlegal requirements:
Legal basis for processing:
Our legitimate interests (Article 6(1)(f) of the GeneralData Protection Regulation).
Legitimate interests:
Preventing crime or suspected criminal activity (such asfraud) and taking steps to enforce our legal rights. Where the legalobligations are part of the laws of another country and have not beenintegrated into the United Kingdom’s legal framework, we have a legitimateinterest in complying with these obligations.
12. Data retention: Personal data
We use your Personal Data to meet our contractualrequirements to support us in providing a data protection service to you. Wealso use your Personal Data as required by law, such as for tax purposes. Wealso use your information to invoice you, and to keep track of payments thatyou make.
We will retain information about you for the duration of ourrelationship with you, then 2 years. Wewill retain financial records for 6 years, following the end of the currentfinancial year for tax purposes.
Otherwise, we will retain your information for no longer thannecessary, taking into account the following:
• the purpose(s) and use of your information both now and inthe future (such as whether it is necessary to continue to store thatinformation in order to continue to perform our obligations under a contractwith you or to contact you in the future);
• whether we have any legal obligation to continue toprocess your information (such as any record-keeping obligations imposed byrelevant law or regulation);
• whether we have any legal basis to continue to processyour information (such as your consent);
• how valuable your information is (both now and in thefuture);
• any relevant agreed industry practices on how longinformation should be retained;
• the levels of risk, cost and liability involved with us continuingto hold the information;
• how hard it is to ensure that the information can be keptup to date and accurate; and
• any relevant surrounding circumstances (such as the natureand status of our relationship with you).
13. Data security: Personal data
We take appropriate technical and organisational measures tosecure your information and to protect it against unauthorised or unlawful useand accidental loss or destruction, including:
• only sharing and providing access to your information tothe minimum extent necessary, subject to confidentiality restrictions whereappropriate, and on an anonymised basis wherever possible;
• verifying the identity of any individual who requestsaccess to information prior to granting them access to information;
• using Secure Sockets Layer (SSL) software to encrypt anyinformation you submit to us via any forms on our website and any paymenttransactions you make on or via our website.
• only transferring your information via closed system or encrypteddata transfers.
Transmission of information to us by email:
Transmission of information over the internet is notentirely secure, and if you submit any information to us over the internet(whether by email, via our website or any other means), you do so entirely atyour own risk. We cannot be responsible for any costs, expenses, loss ofprofits, harm to reputation, damages, liabilities or any other form of loss ordamage suffered by you as a result of your decision to transmit information tous by such means.
14. Data Transfers outside the European Economic Area
All of your information stored on the website is in theEuropean Economic Area (EEA) country–UK Other than to comply with any legalobligations, we do not intend to transfer your information outside the EEA orto an international organisation. In the unlikely event that we are required totransfer your information outside the EEA, we will ensure appropriatesafeguards and protections are in place.
Contact Form:
Information you submit to us via our contact form istransferred inside the UK and stored on our store’s server. Our hostingprovider is Webhosting UK COM Ltd. You can access their privacy policy here.
Country of storage:
Residents of the European Economic Area:
Webhosting UK COM Ltd
Suite 17 Commercial Street
Morley
Leeds
West Yorkshire
LS27 8HX
Email:
Information you submit to us by email is stored within theEEA -UK, Ireland or Belgium. Although due to resiliency and redundancyreasons using a network of data centres.Google mail and Microsoft may also store emails outside the EEA on theirservers. You can access Google's privacy policy here and Microsoft's policyhere.
Country of storage:
This country is not subject to an adequacy decision by theEuropean Commission.
Safeguard(s) used: Google has self-certified its compliancewith the EU-U.S. Privacy Shield.
Google Analytics:
Information collected by Google Analytics (your IP addressand actions you take in relation to our website) is transferred outside the EEAand stored on Google’s servers. You can access Google’s privacy policy here:https://www.google.com/policies/privacy/
Country of storage:
United States of America. This country is not subject to anadequacy decision by the European Commission.Safeguard(s) used: Google hasself-certified its compliance with the EU-U.S. Privacy Shield which isavailable here: https://www.privacyshield.gov/welcome. The EU-U.S. PrivacyShield is an approved certification mechanism under Article 42 of the GeneralData Protection Regulation, which is permitted under Article 46(2)(f) of theGeneral Data Protection Regulation. You can access the European Commissiondecision on the adequacy of the EU-U.S. Privacy Shield here:http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
15. GDPR Individual rights
Subject to certain limitations on certain rights, you havethe following rights in relation to your information, which you can exercise bywriting to Ian Ayliffe, Data protection lead. Address: Promote-UK Ltd, 4 Old Park Lane, Mayfair,London, W1K 1QW. Phone: +44 (0) 345 257 0688 or sending an email to privacy@promoteukltd.com
• to request access to your information and informationrelated to our use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in astructured, commonly used and machine-readable format (e.g. a CSV file) and theright to have that information transferred
• to another data controller (including a third party datacontroller);to object to the processing of your information for certainpurposes;
• to withdraw your consent to our use of your information atany time where we rely on your consent to use or process that information.(lawfulness of use and processing still applies).
In accordance with Article 77 of the General Data ProtectionRegulation, you also have the right to submit a complaint with a supervisoryauthority, in particular in the Member State of your habitual residence, placeof work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is theInformation Commissioner’s Office (ICO), the contact details of which areavailable here: https://ico.org.uk/global/contact-us/
The above rights are provided in summary form only andcertain limitations apply to many of these rights. For further informationabout your rights in relation to your information, including any limitationswhich apply, please visit the following pages on the ICO’s website:
• https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/;and
•https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
• https://ico.org.uk/concerns/
You can also find out further information about your rights,as well as information on any limitations which apply to those rights, byreading the underlying legislation contained in Articles 12 to 22 and 34 of theGeneral Data Protection Regulation, which is available here:http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to yourinformation:
Upon a request to access your information, we are legallyrequired to use all reasonable measures to verify your identity via existinginformation we have on file or we may ask for other forms of identityverification.
16. The right to restrict processing
You have the following rights in relation to yourinformation, which you may exercise in the same way as you may exercise bywriting to the Data protection officer: Ian Ayliffe Address: 4 Old Park Lane, Mayfair, London, W1K 1QWPhone: +44 (0)333 202 7101. Or sending an email to privacy@promoteukltd.com inorder to object to us using or processing your information. Where we use orprocess it in order to carry out a task in the public interest or for ourlegitimate interests, including ‘profiling’ (i.e. analysing or predicting yourbehaviour based on your information) based on any of these purposes; and
• to object to us using or processing your information fordirect marketing purposes (including any profiling we engage in that is relatedto such direct marketing).
You may also exercise your right to object to us using orprocessing your information for direct marketing purposes by:
• clicking the unsubscribe link contained at the bottom ofany marketing email we send to you and following the instructions which appearin your browser following your clicking on that link;
• sending an email to privacy@promoteukltd.com, asking thatwe stop sending you marketing communications or by including the words “OPTOUT”.
For more information on how to object to our use ofinformation collected from cookies and similar technologies, please see thesection entitled "How to accept or reject cookies" in our cookiespolicy.
17. Sensitive Personal Information
We do not knowingly or intentionally collect sensitivepersonal information from individuals.‘Sensitive personal information’ datathat consists of racial or ethnic origin, political opinions, religious orphilosophical beliefs, or trade union membership, genetic data, biometric data,data concerning health or data concerning a natural person's sex life or sexualorientation.
If you have sentsensitive personal information to us, you will be considered to have explicitlyconsented to us processing that sensitive personal information under Article9(2)(a) of the General Data Protection Regulation. This information will bedeleted after data processing.
18. Privacy Policy Updates
We periodically update and amend our Privacy Policy.
Privacy Policy: Minor updates
Where we make minor changes to our Privacy Policy, we willupdate our Privacy Policy with a new effective date stated at the beginning ofit.
Privacy Policy: Major updates
Upon major changes to our Privacy Policy or using yourPersonal Data for a new purpose, we will notify you by email or via a notice onour website, explaining the reason for the change.
19. External Links
We have no control or responsibilities on other websites notowned by us. If you click on a third party link, you will be directed to theirwebsite. It is recommended you review their privacy policy.
20. Children’s Data Privacy Compliance
Our company is compliant with the Children’s Online PrivacyProtection Act of 1998 (COPPA). COPPA regulations protect the privacy ofchildren using the internet. We do not contact or collect data for personsunder the age of 18. However, if we did we immediately obtain the appropriateparental consent to use that information or, if not we will delete theinformation from our servers. If you would like inform us that persons underthe age of 18 has engaged with us via the Internet, please send us anemail.
21. DNT (Do Not Track) Disclosure: The California OnlinePrivacy Protection Act
“Do Not Track” is a web browser privacy preference option.This will send a message to websites requesting that they do not track the user.For further information visit www.allaboutdnt.org
Currently, we do not respond to Do Not Track browsersettings or signals. However, please note your internet activity may still bemonitored via pixels and web beacons. To opt out of these please see ourCookies Policy.
22. How to contact us
If you want to request information about our privacy policyor discuss any data protection issues you can at privacy@promoteukltd.com orwrite to:
Data protection lead: Ian Ayliffe Address: Promote-UK Ltd, 4Old Park Lane, Mayfair, London, W1K 1QW.
Phone: +44 (0) 345 257 0688
23. Your right to complain
Your right to complain to a supervisory authority. You havethe right to take any complaints about how we process your personal data to asupervisory authority.
The UK supervisory authority contact details:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Phone: 0303 123 1113
Further assistance in how to report a concern or a complainthttps://ico.org.uk/concerns/