Privacy Policy,
Data Collection
Policy
and
Cookies Policy
Website privacy notice
INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data through your use of our site founderfoundations.com By providing us with your data, you warrant to us that you are over 13 years of age. ikwe ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Contact Details Our full details are: Full name of legal entity: ikwe ltd, Email address: hello@ikwe.co.uk Postal address: 18 Ewhurst Road London UK SE4 1AQ It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at hello@ikwe.co.uk.
WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business). Sensitive Data We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences. Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at hello@ikwe.co.uk. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing. We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
[Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time. Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at hello@ikwe.co.uk at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below: Service providers who provide IT and system administration services. Professional advisers including lawyers, bankers, auditors and insurers Government bodies that require us to report processing activities. Third parties to whom we sell, transfer, or merge parts of our business or our assets. We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
Where you are within the United Kingdom:
We are subject to the provisions of the UK General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such: We may transfer your personal data to countries that the relevant regulatory authorities in the United Kingdom have approved as providing an adequate level of protection for personal data by; or If we use US-based providers that are part of a UK regulator approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or Where we use certain service providers who are established outside of the UK, we may use specific contracts or codes of conduct or certification mechanisms approved by the United Kingdom regulators which give personal data the same protection it has in the UK. If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Where you are within the EEA:
We are subject to the provisions of the EU General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such: We may transfer your personal data to countries that the European Commission has approved as providing an adequate level of protection for personal data by; or If we use US-based providers that are part of an EU approved privacy framework, we may transfer data to them, as they have equivalent safeguards in place; or Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by EU regulators which give personal data the same protection it has in the EEA. If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
DATA RETENTION We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers. In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. If you are within the UK, you can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at hello@ikwe.co.uk. 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 or refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you are within the UK and are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We s This website 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 notice of every website you visit.
Would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you. If you are within the EU and are not happy with any aspect of how we collect and use your data, you have the right to complain to the data protection authority of the country in which you are based. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
THIRD PARTY LINKS This website 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 notice of every website you visit.
COOKIES You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see
DATA PROTECTION POLICY
INTRODUCTION This Data Protection Policy sets out how ikwe ltd (”we”, “our”, “us”) process the personal data of our customers, prospects, suppliers, employees, workers and other third parties. This Data Protection Policy applies to all personal data we process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject. We commit to the correct and lawful treatment of personal data and to protecting the confidentiality and integrity of personal data. All definitions used in this Data Protection Policy shall have the meaning given in the General Data Protection Regulation ((EU) 2016/679) (“GDPR”).
DATA PROTECTION PRINCIPLES We adhere to the principles relating to the processing of Personal data set out in the GDPR which require personal data to be: (a) processed lawfully, fairly and in a transparent manner (the Lawfulness, Fairness and Transparency principle); (b) collected only for specified, explicit and legitimate purposes (the Purpose Limitation principle); (c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed (the Data Minimisation principle); (d) accurate and where necessary kept up to date (the Accuracy principle); (e) not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is processed (the Storage Limitation principle); (f) processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage (the Security, Integrity and Confidentiality principle); (g) not transferred to another country without appropriate safeguards being in place (the Transfer Limitation principle); and (h) made available to Data Subjects and allow Data Subjects to exercise certain rights in relation to their personal data (Data Subject’s Rights and Requests). We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (the Accountability principle).
LAWFULNESS, FAIRNESS, TRANSPARENCY Personal data must be processed lawfully, fairly and in a transparent manner in relation to the Data Subject. We may only collect, process and share personal data fairly and lawfully and for specified purposes. The GDPR restricts our actions regarding personal data to specified lawful purposes. These restrictions are not intended to prevent processing, but ensure that we process personal data fairly and without adversely affecting the Data Subject. The GDPR allows processing for specific purposes, some of which are set out below: (a) the Data Subject has given his or her consent; (b) the processing is necessary for the performance of a contract with the Data Subject; (c) to meet our legal compliance obligations; (d) to protect the Data Subject’s vital interests; or (e) to pursue our legitimate interests for purposes where they are not overridden because the processing prejudices the interests or fundamental rights and freedoms of Data Subjects. Where we process data under the legitimate interests ground at 4(e) above, the purposes for which we process personal data for legitimate interests are set out in our Privacy Notice. We identify and document the legal ground being relied on for each processing activity and include this in our Privacy Notice.
CONSENT A Data Subject consents to processing of their personal data if they indicate agreement clearly either by a statement or positive action to the processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity will not be sufficient. If consent is given in a document which deals with other matters, then the consent must be kept separate from those other matters. Data Subjects must be easily able to withdraw consent to processing at any time and withdrawal of such consent must be promptly honoured. Consent may need to be refreshed if we intend to process personal data for a different and incompatible purpose which was not disclosed when the Data Subject first consented. When processing Special Category Data or Criminal Convictions Data, we will usually rely on a legal basis for processing other than explicit consent or consent if possible. Where explicit consent is relied on, we will issue a Privacy Notice to the Data Subject that requires signature of the Data Subject to obtain explicit consent. We will evidence consent captured and keep records of all consents so that we can demonstrate compliance with consent requirements. T
RANSPARENCY (NOTIFYING DATA SUBJECTS) The GDPR requires us as a Data Controller to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. The information must be provided through our Privacy Notice which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand it. You can view our Privacy Notice here http://www.ikwe.co.uk Whenever we collect personal data directly from Data Subjects, we must provide the Data Subject with all the information required by the GDPR including the identity of us as the Controller and of the DPO, how and why we will use, process, disclose, protect and retain that personal data. We do this through a Privacy Notice which must be presented when the Data Subject first provides the personal data. When personal data is collected indirectly (for example, from a third party or publicly available source), we must provide the Data Subject with all the information required by the GDPR as soon as possible after collecting or receiving the data. We must also check that the personal data was collected by the third party in accordance with the GDPR and on a basis which contemplates our proposed processing of that personal data. If we collect personal data from Data Subjects, directly or indirectly, then we will provide Data Subjects with a Privacy Notice.
PURPOSE LIMITATION We will only collect and process personal data for specified, explicit and legitimate purposes. It must not be further processed in any manner incompatible with those purposes. We cannot use personal data for new, different or incompatible purposes from that disclosed when it was first obtained unless we have informed the Data Subject of the new purposes and they have consented where necessary.
DATA MINIMISATION Personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. When personal data is no longer needed for specified purposes, it is deleted or anonymised in accordance with our data retention guidelines.
ACCURACY Personal data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate. We ensure that the personal data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We take all reasonable steps to destroy or amend inaccurate or out-of-date personal data.
STORAGE LIMITATION Personal data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed. We will maintain retention policies and procedures to ensure personal data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires that data to be kept for a minimum time. We will not keep personal data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements. We will take all reasonable steps to destroy or erase from our systems all personal data that we no longer require in accordance with all our applicable records retention schedules and policies. This includes requiring third parties to delete that data where applicable. We will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in our Privacy Notice.
SECURITY INTEGRITY AND CONFIDENTIALITY
Personal data must be secured by appropriate technical and organisational measures against unauthorised or unlawful processing, and against accidental loss, destruction or damage. We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of personal data that we own or maintain on behalf of others and identified risks (including use of encryption and pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal data. We will implement reasonable and appropriate security measures against unlawful or unauthorised processing of personal data and against the accidental loss of, or damage to, personal data. We will exercise particular care in protecting Special Categories of personal data and Criminal Convictions Data from loss and unauthorised access, use or disclosure. We will follow all procedures and technologies we put in place to maintain the security of all personal data from the point of collection to the point of destruction. We may only transfer personal data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested. We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows: (a) Confidentiality means that only people who have a need to know and are authorised to use the personal data can access it; (b) Integrity means that personal data is accurate and suitable for the purpose for which it is processed; and (c) Availability means that authorised users are able to access the personal data when they need it for authorised purposes.
REPORTING A PERSONAL DATA BREACH
The GDPR requires us as a Data Controller to notify any personal data breach to the applicable regulator and, in certain instances, the Data Subject. We have put in place procedures to deal with any suspected personal data breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.
TRANSFER LIMITATION
The Data Protection Act 2018 restricts data transfers to countries outside the UK and the EEA to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. Personal data is transferred originating in one country across borders when it is transmitted, sent, viewed or accessed in or to a different country. We may only transfer Personal data outside the UK and the EEA if one of the following conditions applies: (a) the European Commission has issued a decision confirming that the country to which we transfer the Personal data ensures an adequate level of protection for the Data Subject’s rights and freedoms; (b) appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism; (c) the Data Subject has provided explicit consent to the proposed transfer after being informed of any potential risks; or (d) the transfer is necessary for one of the other reasons set out in the GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving consent and, in some limited cases, for our legitimate interest.
DATA SUBJECT’S RIGHTS AND REQUESTS
Data Subjects have rights when it comes to how we handle their personal data. These include rights to: (a) withdraw consent to processing at any time; (b) receive certain information about the Data Controller’s processing activities; (c) request access to their personal data that we hold; (d) prevent our use of their personal data for direct marketing purposes; (e) ask us to erase personal data if it is no longer necessary in relation to the purposes for which it was collected or processed or to rectify inaccurate data or to complete incomplete data; (f) restrict processing in specific circumstances; (g) challenge processing which has been justified on the basis of our legitimate interests or in the public interest; (h) request a copy of an agreement under which personal data is transferred outside of the EEA; (i) object to decisions based solely on automated decision-making, including profiling; (j) prevent processing that is likely to cause damage or distress to the Data Subject or anyone else; (k) be notified of a personal data breach which is likely to result in high risk to their rights and freedoms; (l) make a complaint to the supervisory authority; and (m) in limited circumstances, receive or ask for their personal data to be transferred to a third party in a structured, commonly used and machine-readable format. We must verify the identity of an individual requesting data under any of the rights listed above and will not allow third parties to obtain personal data without proper authorisation.
ACCOUNTABILITY
We must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. We are responsible for, and must be able to demonstrate, compliance with the data protection principles. We must have adequate resources and controls in place to ensure and to document GDPR compliance including: (a) appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy; (b) implementing Privacy by Design when processing personal data and completing DPIAs where processing presents a high risk to rights and freedoms of Data Subjects; (c) integrating data protection into internal documents including this Data Protection Policy and Privacy Notices; (d) regularly training our employees on the GDPR, this Data Protection Policy, related policies and privacy guidelines and data protection matters including, for example, Data Subject’s rights, consent, legal basis, DPIA and personal data breaches. We will maintain a record of training attendance by our employees; and (e) regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort.
RECORD KEEPING
The GDPR requires us to keep full and accurate records of all our data processing activities. These records will include, at a minimum, the name and contact details of us as the Controller and the DPO, clear descriptions of the personal data types, Data Subject types, processing activities, processing purposes, third-party recipients of the personal data, personal data storage locations, personal data transfers, the personal data’s retention period and a description of the security measures in place. To create the records, we create a data map which includes the detail set out above together with appropriate data flows.
TRAINING AND AUDIT
We are required to ensure all of our employees have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.
PRIVACY BY DESIGN AND DATA PROTECTION IMPACT ASSESSMENT (DPIA)
We are required to implement Privacy by Design measures when processing personal data by implementing appropriate technical and organisational measures (like pseudonymisation) in an effective manner, to ensure compliance with data privacy principles. We assess what Privacy by Design measures can be implemented on all programmes, systems or processes that process personal data by taking into account the following: the state of the art; the cost of implementation; the nature, scope, context and purposes of processing; and the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the processing. We also conduct DPIAs in respect to high-risk processing. We will conduct a DPIA when implementing major system or business change programs involving the processing of personal data including: use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes); automated decision-making including profiling; large-scale processing of Special Categories of personal data or Criminal Convictions Data; and large-scale, systematic monitoring of a publicly accessible area. A DPIA includes: a description of the processing, its purposes and the Data Controller’s legitimate interests if appropriate; an assessment of the necessity and proportionality of the processing in relation to its purpose; an assessment of the risk to individuals; and the risk mitigation measures in place and demonstration of compliance.
AUTOMATED DECISION-MAKING
Generally, automated decision-making is prohibited when a decision has a legal or similar significant effect on an individual unless: (a) a Data Subject has explicitly consented; (b) the processing is authorised by law; or (c) the processing is necessary for the performance of or entering into a contract. If certain types of Special Categories of personal data or Criminal Convictions Data are being processed, then grounds (b) or (c) will not be allowed but the Special Categories of personal data and Criminal Convictions Data can be processed where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention. If a decision is to be based solely on automated decision-making (including profiling), then Data Subjects must be informed when you first communicate with them of their right to object. This right must be explicitly brought to their attention and presented clearly and separately from other information. Further, suitable measures must be put in place to safeguard the Data Subject’s rights and freedoms and legitimate interests. We must also inform the Data Subject of the logic involved in the decision making or profiling, the significance and envisaged consequences and give the Data Subject the right to request human intervention, express their point of view or challenge the decision. A DPIA must be carried out before any automated decision-making (including profiling) activities are undertaken.
DIRECT MARKETING
We are subject to certain rules and privacy laws when marketing to our customers or prospects. For example, a Data Subject’s prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as “soft opt-in” allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message. The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information. A Data Subject’s objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future. We comply with all of these rules on marketing.
SHARING PERSONAL DATA
Generally, we are not allowed to share personal data with third parties unless certain safeguards and contractual arrangements have been put in place. We may only share the personal data we hold with third parties, such as our service providers, if: (a) they have a need to know the information for the purposes of providing the contracted services; (b) sharing the personal data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject’s consent has been obtained; (c) the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place; (d) the transfer complies with any applicable cross-border transfer restrictions; and (e) a fully executed written contract that contains GDPR-approved third party clauses has been obtained.
CHANGES TO THIS DATA PROTECTION POLICY
We keep this Data Protection Policy under regular review. This version was last updated on May 1, 2024. This Data Protection Policy does not override any applicable national data privacy laws and regulations in countries where we operate.
COOKIE POLICY
What's a cookie? A "cookie" is a piece of information that is stored on your computer's hard drive if you agree to this and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes. Cookies are used by nearly all websites and do not harm your system. We are required to obtain your consent for all non-essential cookies used on our website. You can block cookies (including essential cookies) at any time 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 essential cookies you may not be able to access all or parts of our site. How do we use cookies? We use cookies to track your use of our website. This enables us to understand how you use the site and track any patterns with regards how you are using our website. This helps us to develop and improve our website as well as products and / or services in response to what you might need or want. Cookies are either: - Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or - Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics.
Cookies can also be categorised as follows:
- Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
- Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
- Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
- Targeting 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.
- First and third party cookies: First party cookies are cookies set by our website. Third party cookies are cookies on our website that are set by a website other than our website, such as where we have adverts on our website or use Facebook pixels so that we can show you relevant content from us when you are on Facebook.
