Terms and Conditions

Our terms and conditions, privacy policy, cookie policy and more.

Terms and Conditions

Terms and Conditions

Cotswold Park Barns

Website Terms of Use

PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE USING THIS SITE

These terms tell you the rules for using our website https://www.cotswoldparklodge.co.uk/ (our site). Please also see our Acceptable use policy at the end of this document.

Who we are and how to contact us

https://www.cotswoldparklodge.co.uk/ is a site operated by Cotswold Park Barns ("We"). We are registered in England and Wales under company number  and have our registered office at Cotswold Park Lodge Woodmancote Cirencester GB GL7 7EL United Kingdom. Our main trading address is Cotswold Park Lodge Woodmancote Cirencester GB GL7 7EL United Kingdom. Our VAT number is 155026628.

To contact us, please email simon@cotswoldparkbarns.co.uk or call 01285 831 433.

By using our site you accept these terms

By using our site, you confirm that you accept these terms of use and that you agree to comply with them.

If you do not agree to these terms, you must not use our site.

We recommend that you print a copy of these terms for future reference.

There are other terms that may apply to you

These terms of use refer to the following additional terms, which also apply to your use of our site:

  • Our Privacy Policy: https://www.cotswoldparklodge.co.uk/terms#privacy.

  • Our Cookie Policy: https://www.cotswoldparklodge.co.uk/terms#cookies.

We may make changes to these terms

We amend these terms from time to time. Every time you wish to use our site, please check these terms to ensure you understand the terms that apply at that time. 

We may make changes to our site

We may update and change our site from time to time to reflect changes to our services, our users’ needs and our business priorities.

We may suspend or withdraw our site

We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of our site for business and operational reasons. We will try to give you reasonable notice of any suspension or withdrawal.

You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.

We may transfer this agreement to someone else

We may transfer our rights and obligations under these terms to another organisation. We will always tell you in writing if this happens and we will ensure that the transfer will not affect your rights under the contract.

You must keep your account details safe

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party.

We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of these terms of use.

If you know or suspect that anyone other than you knows your user identification code or password, you must promptly notify us at simon@cotswoldparkbarns.co.uk or 01285 831 433.

How you may use material on our site

We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

You may print off one copy, and may download extracts, of any page(s) from our site for your personal use and you may draw the attention of others within your organisation to content posted on our site.

You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.

Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged (except where the content is user-generated).

You must not use any part of the content on our site for commercial purposes without obtaining a licence to do so from us or our licensors.

If you print off, copy, download, share or repost any part of our site in breach of these terms of use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

No text or data mining, or web scraping

You shall not conduct, facilitate, authorise or permit any text or data mining or web scraping in relation to our site or any services provided via, or in relation to, our site. This includes using (or permitting, authorising or attempting the use of):

  • Any "robot", "bot", "spider", "scraper" or other automated device, program, tool, algorithm, code, process or methodology to access, obtain, copy, monitor or republish any portion of the site or any data, content, information or services accessed via the same.

  • Any automated analytical technique aimed at analysing text and data in digital form to generate information which includes but is not limited to patterns, trends and correlations.

The provisions in this clause should be treated as an express reservation of our rights in this regard.

This clause shall not apply insofar as (but only to the extent that) we are unable to exclude or limit text or data mining or web scraping activity by contract under the laws which are applicable to us.

Do not rely on information on this site

The content on our site is provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site.

Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up to date.

We are not responsible for websites we link to

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.

We have no control over the contents of those sites or resources.

User-generated content is not approved by us

This website may include information and materials uploaded by other users of the site, including to social media pages, video-sharing sites, bulletin boards and chat rooms. This information and these materials have not been verified or approved by us. The views expressed by other users on our site do not represent our views or values.

Uploading content to our site

Whenever you make use of a feature that allows you to upload content to our site and/or otherwise leave comments or feedback, or to make contact with other users of our site, you must comply with all applicable laws. In addition, you must not upload content or otherwise make contributions to our site that: 

  • is unlawful or serves an unlawful purpose including terrorism or extremism, harmful, threatening, defamatory, obscene, infringing, harassing or racially or ethnically offensive;

  • facilitates illegal activity;

  • is in breach of any applicable local, national or international law or regulation;

  • depicts sexually explicit images;

  • harms minors;

  • promotes unlawful violence, intimidation or bullying;

  • is discriminatory based on race, gender, gender identity, age, colour, religious belief, sexual orientation, disability; 

  • is defamatory; 

  • infringes third party intellectual property rights; or

  • is otherwise illegal or causes damage or injury to any person or property;

and we reserve the right, without liability or prejudice to our other rights, to disable your access to any material and/or remove any content or contribution that constitutes the same.

You warrant that any such contribution you make to our site complies with our standards (we may issue content standards from time to time) and does not breach the above list, and you will be liable to us and indemnify us for any breach of that warranty. This means you will be responsible for any loss or damage we suffer as a result of your breach of warranty.

Any content you upload to our site will be considered non-confidential and non-proprietary. You retain all of your ownership rights in your content, but you are required to grant us and other users of our site a limited licence to use, store and copy that content and to distribute and make it available to third parties. 

We also have the right to disclose your identity to any third party who is claiming that any content posted or uploaded by you to our site constitutes a violation of their intellectual property rights, or of their right to privacy.

We have the right to remove any posting you make on our site if, in our opinion, your post does not comply with our content standards.

You are solely responsible for securing and backing up your content.

We do not store terrorist content.

Rights you are giving us to use material you upload

When you upload or post content to our site, you grant us a worldwide, non-exclusive, royalty-free, transferable licence to use, reproduce, distribute, prepare derivative works of, display, and perform that user-generated content in connection with the service provided by the website and across different media including to promote the site or the service to expire when the user deletes the content from the site;

Our responsibility for loss or damage suffered by you

  • We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.

  • Please note that we have no liability to you for any loss of profit, loss of business, business interruption, or loss of business opportunity. 

How we may use your personal information

We will only use your personal information as set out in our https://www.cotswoldparklodge.co.uk/terms#privacy.

We are not responsible for viruses and you must not introduce them

We do not guarantee that our site will be secure or free from bugs or viruses.

You are responsible for configuring your information technology, computer programmes and platform to access our site. You should use your own virus protection software.

You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.

Rules about linking to our site

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.

If you are interested in linking to our website, you must inform us by sending an e-mail to simon@cotswoldparkbarns.co.uk. Please include your name, your organisation name, contact information as well as the URL of your site, a list of any URLs from which you intend to link to our Site, and a list of the URLs on our site to which you would like to link. Our response may take up to [TIME].

Once approval has been obtained, you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists, and we may withdraw permission without notice at any time. 

You must not establish a link to our site in any website that is not owned by you.

Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page.

We reserve the right to withdraw linking permission without notice.

The website in which you are linking must comply in all respects with the content standards set out in our Acceptable Use Policy below.

If you wish to link to or make any use of content on our site other than that set out above, please contact simon@cotswoldparkbarns.co.uk.

Which country's laws apply to any disputes?

If you are a consumer, please note that these terms of use, their subject matter and their formation, are governed by English law. You and we both agree that the courts of England and Wales will have exclusive jurisdiction.

If you are a business, these terms of use, their subject matter and their formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.


Acceptable Use Policy

PLEASE READ THE TERMS OF THIS POLICY CAREFULLY BEFORE USING THE WEBSITE. BY ACCESSING THE WEBSITE, YOU ACCEPT THESE TERMS WHICH BIND YOU. 

  1. What’s in these terms

    1.1 This acceptable use policy sets out the content standards that apply when you use our service, including (but not limited to) the input of data and information, or uploading content, to our Website contacting other users on our Website, link to our Website, or interact with our Website in any other way (these “Terms”).

    1.2 It should be read alongside our website terms and conditions: .

    1.3 These Terms are provided by Cotswold Park Barns (“us / we / our”).
  2. By using our Website you accept these Terms
    By using our Website: https://www.cotswoldparklodge.co.uk/, you accept the Terms of this policy and that you agree to comply with them. If you do not agree to these Terms, you must not use our Website. 

  3. We may make changes to the Terms of this policy
    We amend these Terms from time to time. Every time you wish to use our Website, please check these Terms to ensure you understand the Terms that apply at the time.

  4. Prohibited uses

    4.1 For the purposes of this section, the defined term “Intellectual Property Rights” shall mean rights to inventions, copyright and related rights, moral rights, trade marks, business names and domain names, rights in get-up and trade dress, goodwill and the right to sue for passing off or unfair competition, rights in designs, rights in computer software, computer generated works, algorithms, database rights, rights to use, and protect the confidentiality of, confidential information (including know-how and trade secrets), and all other intellectual property rights, in each case whether registered or unregistered and including all applications and rights to apply for and be granted, renewals or extensions of, and rights to claim priority from, such rights and all similar or equivalent rights or forms of protection which subsist or will subsist now or in the future in any part of the world.

    4.2 Use of our Website shall be in accordance with our terms of website use

    4.3 You may not use our Website:

    To process or disclose personal data which has not been requested by us (“personal data” has the meaning given to it in the Data Protection Act 2018); 

    a) To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

    b) To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
    1. To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards set out in clause Content standards.

    2. In any way that breaches any applicable local, national or international law or regulation, that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect.

    3. Except as specifically allowed for by law or within these Terms, you shall not, (and shall not attempt to);

      1. copy, modify, duplicate, create derivative works from, frame, mirror, republish, publish, download, display, transmit, or distribute all or any portion of the Website including any (or any part of its) contents in any form or by any means, except where permitted within the functionality of the Website; or

      2. reverse compile, disassemble, reverse engineer or otherwise reduce to human-perceivable form all or any part of the Website; or

      3. access all or any part of the Website (including any modules) in order to build a product or service which competes with the Website; or

      4. use the Website to commit plagiarism; or 

      5. license, sell, rent, lease, transfer, assign, distribute, display, disclose, or otherwise commercially exploit, or otherwise make the Website available (and/or any of its contents) to any third party; or

      6. use the Website within a software application, website or software which competes with our operations; or

      7. exceed the indicated storage capability of the Website (as notified to you from time to time);

      8. use screen-recording technology to record and/or capture your use of the Website; 

      9. attempt to obtain, or assist third parties in obtaining, access to the Website; or

      10. in respect of the Website, perform stress tests or similar load testing.

    4. You must not:

      1. infringe our Intellectual Property Rights, including those arising in the Website or its contents, or the Intellectual Property Rights of any third party in relation to use of the Website or its contents;

      2. use our Intellectual Property Rights, other than as permitted under these Terms, without our prior written consent;

      3. permit any third party, to infringe our Intellectual Property Rights or the Intellectual Property Rights of any third party in relation to their use of the Website;

      4. scrape any part of the Website or its contents; 

      5. use the Website in a way that could damage, disable, overburden, impair or compromise our systems or security or interfere with other users; and

      6. collect or harvest any information or data from the Website or our systems or attempt to decipher any transmissions to or from the servers. 

      7. you understand that any information, data or content input onto the Website will be viewable by us, the primary licensee and such other authorised persons that we may permit from time to time.

    5. For the avoidance of doubt, nothing in these Terms should be construed as authority for you to use our Intellectual Property Rights, save for access and use of the Website (which is provided as is) and/or as otherwise agreed by us. 

    6. You are not permitted to use our branding, trade marks and/or logos and we reserve our right to enforce our intellectual property rights against you should you do so. 

  5. Content standards

    5.1 These content standards apply to any and all material which you contribute, interact with and/or otherwise upload to our Website and in general, your use of the Website (“Contribution”).

    5.2 We will determine, in our discretion, whether a Contribution breaches these content standards.

    5.3 A Contribution must:

       a) Be accurate (where it states facts).

       b) Be genuinely held (where it states opinions).

       c) Comply with the law applicable in England and Wales and in any country from which it is used and/or posted.

    5.4 A Contribution must not:

       a) Be defamatory, obscene, offensive, hateful, inflammatory, bully, insult, annoy intimidate or humiliate.

       b) Be threatening, abuse or invade another's privacy.

       c) Promote any illegal content or activity, including but not limited to financial crime, violence, terrorism or sexual exploitation. 

       d) Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age. Impersonate any person or misrepresent your identity or affiliation with any person  including giving the impression that the Contribution emanates from us, if this is not the case.

       e) Infringe any Intellectual Property Rights of any other person.

       f) Breach any legal duty owed to a third party, such as a contractual duty or a duty of confidence.

       g) Impersonate any person or misrepresent your identity or affiliation with any person  including giving the impression that the Contribution emanates from us, if this is not the case.
  6. Breach of this policy

    6.1 Failure to comply with this acceptable use policy constitutes a material breach of any other agreement entered in respect of the Website, and may result in our taking all or any of the following actions:

       a) Issue of a warning to you.

       b) Immediate, temporary or permanent withdrawal of your right to use our Website.

       c) Immediate, temporary or permanent removal of any Contribution uploaded by you to our Website.

       d) The commencement of legal action against you.

    6.2 We exclude our liability for all action we may take in response to breaches of this acceptable use policy. The actions we may take are not limited to those described above, and we may take any other action we reasonably deem appropriate.
     
  7. How this contract can be transferred
    We can transfer our rights and obligations under these Terms to any third party, provided this does not adversely affect your rights under these Terms.
  8. Which country's laws apply to any disputes?
    The Terms of this policy, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law. We both agree to the exclusive jurisdiction of the courts of England and Wales.

Privacy Policy

Cotswold Park Barns

Privacy Policy - version 1

 

  1. INTRODUCTION AND IMPORTANT INFORMATION

Cotswold Park Barns (“we”, “us” or “our”) are committed to protecting and respecting your personal data and privacy. 

This privacy policy relates to how we use and collect personal data from you when you use or purchase our services, or access our website. It also relates to our use of any personal information you provide to us by telephone (including SMS), in written correspondence (including letter and email) and in person. 

Please note that: 

  • our services and our website are not intended for children under the age of 18 and we do not collect data relating to children; and 

  • our website and services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information; including but not limited to the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR), described in this policy as the “Data Protection Laws”.

This privacy policy also forms part of our terms of business and is not intended to override them. This policy may be amended or updated from time to time and any revisions will be posted to this page, so please check back regularly. 

  1. WHO WE ARE AND HOW TO CONTACT US

2.1 For the purpose of the Data Protection Laws, the data controller is [INSERT]. We are a private limited company registered in England and Wales under company number . Our registered office is at Cotswold Park Lodge Woodmancote Cirencester GB GL7 7EL United Kingdom. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:

FAO: [Privacy Officer]

[INSERT]

United Kingdom

Email: simon@cotswoldparkbarns.co.uk

Telephone: 01285 831 433 and ask to speak to the Privacy Officer.  


2.2 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.

  1. The data we collect about you

3.1 We collect and process personal data. Typically the personal data we collect and process will include identity, contract, transactional, technical, profile, usage and marketing and communications data such as: 

3.1.1 Identity Data includes first name, last name, title or other identifier (such as job title), marital status, date of birth, gender and images.

3.1.2 Contact Data includes billing address, email addresses and telephone numbers.

3.1.3 Transaction Data includes details about services you have purchased from us or your visits to our premises.

3.1.4 Financial Data includes bank account and payment card details.

3.1.5 Technical Data includes internet protocol (IP) address, your login data, 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.

3.1.6 Profile Data includes your username and password, purchases or orders made by you, your interests, preferences (including details about your personal likes and dislikes as identified during your visits to our premises), feedback and survey responses.

3.1.7 Usage Data includes information about how you use our website, products and services.

3.1.8 Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferenes.

Please note that we may collect and/or process other personal data from time to time. 

3.2 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 to be personal data in law as it will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate a percentage of users accessing a specific feature of our services. However, if we combine or connect your aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used solely in accordance with this policy.

3.3 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.

3.4 We only collect data from you directly or via third parties (see the section Third Parties below).

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

4.1 We use different methods to collect data from and about you including through:

4.1.1 Direct interactions. You may give us your Identity, Contact, Profile and Financial Data by filling in forms or by corresponding with us by post, phone, messaging service, email or otherwise. This includes personal data you provide when you:

(a) apply for our services;

(b) create an account on our website;

(c) subscribe to our service;

(d) request marketing to be sent to you;

(e) enter a promotion or survey; or

(g) give us feedback or contact us.

4.1.2 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 and other similar technologies. Please see our cookie policy  for further details.

4.1.3 Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

(a) Technical Data from the following parties:

  1. analytics providers;

  2. advertising networks; and

  3. search information providers.

(b) Contact, Financial and Transaction Data from providers of technical, or payment services.

(c) Identity and Contact Data from data brokers or aggregators, including trade organisations or exhibition organisers.

(d) Identity and Contact Data from publicly available sources such as Companies House.

  1. IF YOU FAIL TO PROVIDE PERSONAL DATA

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 our services). In this case, we may have to cancel all or part of a service you have with us but we will notify you if this is the case at the time.

  1. HOW YOUR DATA WILL BE USED

6.1 We use information held about you to: 

6.1.1 carry out our obligations arising from any contracts entered into between you and us and provide our services, including any third party services we make available to you; 

6.1.2 carry out feedback and research on our services; and

6.1.3 notify you about changes to our services.

6.2 We never sell your data to third parties or allow third parties to contact you without your permission. 

6.3 We share your data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis as set out in the table below (please also see clause 7 below). We may process your personal data without your knowledge or consent where this is required or permitted by law.

6.4 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. 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 where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new user or customer. 

Identity

Contact

Performance of a contract with you

To provide our services to you and to process related transactions, including:

Manage payments, fees and charges

Collect and recover money owed to us

Identity

Contact

Transaction

Usage

Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy policy

Asking you to leave a review or take a survey

Identity

Contact

Profile

Marketing and Communications

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a competition or complete a survey

Identity

Contact

Profile

Usage

Marketing and Communications

Performance of a contract with you

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Identity

Contact

Technical

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)

Necessary to comply with a legal obligation

To measure or understand the effectiveness of the advertising we serve to you

Identity

Contact

Profile

Usage

Marketing and Communications

Technical

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

Technical

Usage

Profile

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

Identity

Contact

Technical

Usage

Profile

Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)


 

 

  1. LAWFUL BASIS FOR PROCESSING

    7.1 We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:

7.1.1 Contractual obligation – means processing that is necessary to comply with our obligations arising out of a contract, for example, where you have bought services from us we will use the personal data you provide to fulfil our contractual obligations.

7.1.2 Legitimate Interest - means in 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 you personal data for our legitimate interests. Where we use legitimate interests we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. keeping you up to date with our latest services or obtaining your feedback on our service.

7.1.3 Consent – We will seek to obtain your consent to process:

(a) your data outside our contractual obligations (see above) unless we have identified a Legitimate Interest (see above); and

(b) any special category data.

7.1.4 Legal obligation – We may process your data where we it is necessary for us to do so to comply with the law. 

We may also use your personal data in the following circumstances, which are likely to be rare:

7.1.4.1 Where we need to protect your vital interests (or someone else’s vital interests); or

7.1.4.2 Where it is needed in the public interest.

  1. THIRD PARTIES AND SHARING INFORMATION

8.1 We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you.  We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.

8.2 Please see below the list which sets out the categories of recipients of personal data.

  SERVICE PROVIDERS WHO MAY RECEIVE YOUR PERSONAL DATA

  • IT Support Services
  • Email Provider
  • Website Provider
  • Secure document disposal service
  • Banks
  • Online payment providers
  • Accountants
  • Insurers
  • Solicitors
  • Software Providers
  • Feedback aggregators and collectors
  • Couriers 
  • Marketing Agencies
  1. MARKETING

    1. 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).

    2. 2 You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

    3. 3 We strive to provide you with choices regarding certain personal data uses, namely around marketing and advertising. In particular:

      1. 3.1 We will always obtain your express opt-in consent before we share your personal data with any third party for marketing purposes; and

      2. 3.2 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 your or by contacting us at any time.

  2. INTERNATIONAL TRANSFERS

    10.1 Your data is stored by us in the UK. However, several of our external third parties are based outside of the UK, including in the European Economic Area.

    10.2 Whenever we transfer your personal data to the EEA, we ensure a similar degree of protection is afforded to it by ensuring we only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.


    10.3 Whenever we transfer your personal data to countries outside of the UK and EEA, where we use certain service providers (see clause 8.2), we will rely on an appropriate international data transfer mechanism approved by the UK regulatory authority, the Information Commissioner’s Office.

    10.4 Please contact us using the details provided in clause 2.1 for further information on the specific international data transfer mechanisms that we rely on when sending personal data outside of the UK.

     

  3. DATA SECURITY

    11.1 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.

    11.2 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.

     

  4. DATA RETENTION

    12.1 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.

    12.2 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.


    12.3 By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being clients.

    12.4 In some circumstances you can ask us to delete your data (see below for further information).

    12.5 We may anonymise 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. Please see clause 3.2.

  5. YOUR RIGHTS

    13.1 Under the data protection laws your rights are:

    13.1.1 To be informed – We must make this privacy policy (sometimes referred to as a privacy notice) available to you and be transparent over how we process your data. 

    13.1.2 Access – You are entitled to know what details we hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. You can find out if we hold any of their personal data by making a formal request under the data protection laws. Such requests should be made using the contact details provided in this policy. If we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing. Our response will:

    (a) confirm that your data is being processed;
    (b) verify the lawfulness and the purpose of the processing;
    (c) confirm the categories of personal data being processed;
    (d) confirm the type of recipient to whom the personal data have been or will be disclosed; and
    (e) let you have a copy of the data in format we deem suitable or as reasonably required by you.

    13.1.3 Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.

    13.1.4 Erasure – This is also known as the right to be forgotten. Under Data Protection Laws you have the right to require us to erase your personal data under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this policy.

    13.1.5 Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data.

    13.1.6 Portability – You have the right to obtain the personal data that you have provided to us in a commonly used machine-readable format and reuse it with a different provider. 

    13.1.7 Object – You have the right to object to us processing your data in certain circumstances. You have an absolute right to stop your data being used for direct marketing, but in other circumstances we may still be allowed (or required) to process your personal data if we can show you that we have a compelling reason for doing so.

    13.1.8 Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling.

    13.1.9 Withdraw consent. Where you have given us consent to process your personal data, you can withdraw that consent at any time either by contacting us using the details set out in this policy, or by following the opt-out links in electronic messages where relevant. We do not penalise individuals who wish to withdraw consent and we act on withdrawals of consent as soon as we can. 

    13.2 Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the data protection laws and as summarised above.

    13.3 If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

  6. APPLICATIONS TO WORK FOR US

If you apply to work for us (directly or indirectly) in any role we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.

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