1. Definitions and Interpretation In this Policy the following terms shall have the following meanings:” Account ”means an account required to access and/or use certain areas and features of Our Site;” Cookie ”means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and” Cookie Law ”means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;” personal data ”means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and” We/Us/Our ”means KR Consults Data Protection Officer: Mr Lewis Ramsier. Email address: firstname.lastname@example.org
- Email address;
- Telephone number;
- Business name;
- Job title;
- Information about your preferences and interests;
- IP address;
- Web browser type and version;
- Operating system; and
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
7. How Do You Use My Personal Data? Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your access to Our Site.
- Supplying Our services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by clicking unsubscribe in the relevant email or notifying us at email@example.com.
- Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or telephone with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties. We do not use automated systems for carrying out decision-making.8. How Long Will You Keep My Personal Data? We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept): (a). The objectives and requirements of the Company; (b). The type of personal data in question; (c). The purpose(s) for which the data in question is collected, held, and processed; (d). The Company’s legal basis for collecting, holding, and processing that data; and (e). The category or categories of data subject to whom the data relates. 8.1.1 If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria. 8.1.2 Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise). 8.1.3 In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR. 9. How and Where Do You Store or Transfer My Personal Data? We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows. We share your data within the group of companies of which We are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission. Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country. The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following: Technical Data Security Measures
- All emails containing Personal Data must be encrypted;
- All emails containing Personal Data must be marked ‘confidential’;
- Personal Data may only be transmitted over secure networks;
- Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;
- Personal Data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;
- Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;
- Where Personal Data is to be transferred in hardcopy form, it should be passed directly to the recipient in accordance with this Policy;
- All Personal Data transferred physically should be transferred in a suitable container marked “confidential”;
- No Personal Data may be shared informally and if access is required to any Personal Data, such access should be formally requested from the DPO;
- All hardcopies of Personal Data, along with any electronic copies stored on physical media should be stored securely;
- No Personal Data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;
- Personal Data must be handled with care at all times and should not be left unattended or on view;
- Computers used to view Personal Data must always be locked before being left unattended;
- No Personal Data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the DPO and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;
- No Personal Data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR;
- All Personal Data stored electronically should be backed up regularly with backups stored onsite. All backups should be encrypted;
- All electronic copies of Personal Data should be stored securely using passwords and encryption;
- All passwords used to protect Personal Data should be changed regularly and should must be secure;
- Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
- All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;
- No software may be installed on any Company-owned computer or device without approval; and
- Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the DPO to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.
10. Do You Share My Personal Data? We may share your personal data with other companies in our group to provide our services to you. This includes our holding company and its subsidiaries. We may sometimes contract with the following third parties to supply certain products and/or services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold including:
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for Analytics and Visitor trending. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them. All Cookies used by and on Our Site are used in accordance with current Cookie Law. Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies. Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
Our Site uses analytics services provided by www.Google.com Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the services offered through it. The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) the following Cookies:Name of CookieFirst / Third PartyProviderPurposeGoogleThirdGoogleVisitor AnalysisIn addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies.
By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our Site more quickly and efficiently including, but not limited to, login and personalisation settings. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.15.
How Do I Contact You? To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details