Privacy Policy
TECH TIGER GROUP LTD
PRIVACY NOTICE
ABOUT THIS NOTICE
Tech Tiger is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully.
Data protection law says that the personal information we hold about you must be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely
If you have any questions about this notice or how we collect and use personal information about you please contact us.
1 INFORMATION ABOUT US
1.1 We are Tech Tiger Group Ltd. Our registered office is at 7 Blenheim Court, Brownfields, Welwyn Garden City, AL7 1AD and our registered company number is 13490214.
1.2 If you have any questions, you can contact us at support@tech-tiger.co.uk, or on +44 20 4538 4425.
2 CONTRACT INFORMATION AND OTHER CORRESPONDENCE
2.1 If you are an individual, when you enter into a contract with us (or someone does so on your behalf) there will be personal information about you relating to that contract such as your name, contact details, contract details, delivery details, and correspondence with us about the contract.
2.2 If you are an individual, we need certain information to carry out our contract with you and you must provide this in order to enter into a contract with us (or as required under that contract), if you do not, we may not be able to carry out our contract with you. Mandatory information fields are generally set out when you are entering into the contract, but in particular, you must provide the following information:
2.2.1 Your name and contact details.
2.2.2 Your delivery and billing address.
2.3 Other correspondence or interaction (for example by email, telephone, post, SMS or via our website) between you and us, will include personal information (such as names and contact details) in that correspondence. This may include enquiries, reviews, follow-up comments or complaints lodged by or against you and disputes with you or your organisation.
2.4 Call information. We may also collect details of phone numbers used to call our organisation and the date, time and duration of any calls. Please note that if we record your calls to or from us, we will inform you of this.
2.5 We will keep and use that information to carry out our contract with you (if applicable), to comply with any legal requirements for us to maintain certain records or carry out certain verifications and money laundering checks, and/or for our legitimate interests in preventing fraud, dealing with a complaint or enquiry and administering your (or your organisation's) account or order and any services we offer, as well as to review and improve our offerings, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
2.6 Your information is kept for a period of up to 7 years after your last interaction with us to enable us to deal with any after sales enquiries or claims and as required for tax purposes.
2.7 Payment information is collected by our payment services providers and is retained by them in accordance with their policies. We do not collect or access your card information.
3 MARKETING
3.1 We only use your details to send marketing emails or texts to you if we have your consent to do so. In some circumstances, a third party might have collected that consent on our behalf (for example by allowing you to opt into our marketing emails through their website) but they will always make this clear to you and give you a choice.
3.2 You always have the right to "opt out" of receiving our marketing. You can exercise the right at any time by contacting us. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you "opt-out" of our marketing materials you will be added to our suppression list to ensure we do not accidentally send you further marketing. We may still need to contact you for administrative or operational purposes, but we will make sure that those communications don't include direct marketing.
3.3 We never share your name or contact details with third parties for marketing purposes unless we have your "opt-in" consent to share your details with a specific third party for them to send you marketing. We do use third party service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
3.4 We retain your details on our marketing list until you "opt-out" at which point we add you to our suppression list. We keep that suppression list indefinitely to comply with our legal obligations to ensure we don't accidentally send you any more marketing.
3.5 When we send marketing emails to you, we use "web beacons" to collect information about when you open the email, your IP address and browser or email client type, and other similar information. We do this as necessary for our legitimate interests in reviewing and improving our direct marketing activities.
4 WEBSITE INFORMATION
4.1 We may collect information about you and your use of our website via technical means such as cookies, webpage counters and other analytics tools. This may include your IP address, 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 a website as well as the date and time of your access, what you interact with on our website, and the website from which access is made. We use this as necessary for our legitimate interests in administering and improving our website and its content, to ensure it operates effectively and securely, to develop our business and inform our marketing strategy, and for other administrative purposes. We may also create aggregate statistical data from that information (for instance, overall numbers of website visitors) which is not personal information about you.
4.2 Cookies. The information described above about your use of our website may also be collected and used by third party advertisers and analytics providers using cookie technology. You will have the option when using our website to accept or reject those cookies. If you accept those cookies, your data will be collected and used by those third parties for their own advertising and analytical purposes. For more information, please see their privacy policies.
4.3 What is a cookie? A cookie is a small text file stored by your web browser on your computer or mobile device. Some cookies are essential for a website to work and help us provide you with relevant information. They also allow us to recognise your computer (but not specifically who is using it) when you access our site and to improve the usability and performance of our site. For more detailed information about cookies please visit www.allaboutcookies.org which provides guidance on how to control cookies.
4.4 Turning off and deleting cookies. When you use our site, we’ll give you the opportunity to consent to all of the cookies we’ve listed above (except for strictly necessary cookies). You can also refuse to accept any cookies by activating the setting on your browser which allows you to refuse the setting of cookies. If you select this setting you may be unable to access certain parts of our sites. If you use different devices to view and access our sites (for example, your computer, smart phone, tablet etc.) you will need to ensure that each browser on each device is adjusted to suit your cookie preferences. If you disable the cookies that we use, this may impact your experience while on the sites.
4.5 Blocking cookies. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our site.
4.6 What do we use cookies for? We use cookies to compile anonymous, aggregated statistics that allow us to understand how people use our sites and to help us improve their structure and content. We do not attempt to identify you personally from this information. We have set out below some common types of cookies:
· Strictly required cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
· Analytical/statistics cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
· Functional cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
· Marketing and Retargeting 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. These cookies may also be provided by third parties for them to record your interactions with our website and make their advertising more relevant to your interests.
4.7 You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|
Cookie Name |
Purpose |
More Information |
Duration |
|
_Brochure_session |
Required |
Used in connection with browsing through site. |
- |
|
Checkout |
Required |
Used in connection with Pay checkout on shop.app. |
3w |
|
signed_in |
Required |
Used in connection with Shop login. |
1y |
|
user |
Required |
Used in connection with Shop login. |
1y |
|
_landing_page |
Analytical |
Tracks landing pages. |
|
|
_orig_referrer |
Analytical |
Tracks landing pages. |
|
|
_s |
Analytical |
Shopify analytics. |
|
|
_session_id |
Analytical |
Shopify analytics |
|
|
_shopify_s |
Analytical |
Shopify analytics. |
|
|
_shopify_sa_t |
Analytical |
Shopify analytics relating to marketing & referrals. |
|
|
_shopify_uniq |
Analytical |
Shopify analytics. |
|
|
_shopify_y |
Analytical |
Shopify analytics. |
|
|
_y |
Analytical |
Shopify analytics. |
|
|
*_assignment |
Analytical |
Shopify analytics |
|
|
ab_test_* |
Analytical |
Shopify analytics. |
|
|
cart_sig |
Analytical |
Shopify analytics. |
|
|
ki_r |
Analytical |
Shopify analytics. |
|
|
ki_t |
Analytical |
Shopify analytics. |
|
|
Cloudflare |
Functional |
Shopify uses Cloudflare Network as a Service for edge routing. |
|
|
Disqus |
Functional |
We use Disqus to provide commenting capabilities on posts on our websites. https://help.disqus.com/terms-and-policies/disqus-privacy-policy |
|
|
Facebook Connect |
Functional |
We use Facebook Connect to allow visitors to our website to interact with and share content via Facebook’s social media platform. https://www.facebook.com/policy.php |
|
|
Gravatar |
Functional |
We use Gravatar to allow visitors to our websites to create avatars. https://en.gravatar.com/site/privacy |
|
|
|
Functional |
We use Twitter to allow visitors to our website to interact with and share content via Twitter’s social media platform. https://twitter.com/en/privacy |
|
|
Wistia |
Functional |
We use Wistia to display video content. https://wistia.com/privacy |
|
|
Alexa Metrics |
Reporting |
We use Alexa Metrics to help measure how users interact with our websites. https://www.alexa.com/help/privacy |
|
|
Bizible |
Reporting |
We use Bizible to help measure how users interact with our websites. https://documents.marketo.com/legal/privacy/ |
|
|
Bugsnag |
Reporting |
We use Bugsnag to help us troubleshoot and fix issues with our websites. https://docs.bugsnag.com/legal/privacy-policy/ |
|
|
Chartbeat |
Reporting |
We use Chartbeat to help measure how users interact with our websites. https://chartbeat.com/privacy/ |
|
|
Crazy Egg |
Reporting |
We use Crazy Egg to help measure how users interact with our websites. https://www.crazyegg.com/privacy |
|
|
DC Analytics |
Reporting |
We use DC Analytics to help measure how users interact with our websites. https://dcanalytics.dcmn.com/privacy-policy |
|
|
Facebook Pixel |
Reporting |
We use Facebook Pixel to help measure how users interact with our websites. https://www.facebook.com/privacy/explanation |
|
|
Fullstory |
Reporting |
We use Fullstory to help measure how users interact with our websites. https://www.fullstory.com/legal/privacy/ |
|
|
Google Analytics |
Reporting |
We use Google Analytics to help measure how users interact with our websites. https://policies.google.com/privacy |
|
|
Google Tag Manager |
Reporting |
We use Google Tag Manager to help manage analytics vendors. https://policies.google.com/privacy |
|
|
Hotjar |
Reporting |
We use Hotjar to help measure how users interact with our websites. https://www.hotjar.com/legal/policies/privacy |
|
|
KissInsights |
Reporting |
We use KissInsights to help measure how users interact with our websites. https://signin.kissmetrics.com/privacy/ |
|
|
LinkedIn Insight Tag |
Reporting |
We use LinkedIn Insight Tag to help measure how users interact with our websites. https://www.linkedin.com/legal/privacy-policy |
|
|
New Relic |
Reporting |
We use New Relic to help measure how users interact with our websites. https://newrelic.com/termsandconditions/privacy |
|
|
Optimizely |
Reporting |
We use Optimizely to help us test improvements or changes to our websites. https://www.optimizely.com/privacy/ |
|
|
Pinterest Analytics |
Reporting |
We use Pinterest Analytics to help measure how users interact with our websites. https://policy.pinterest.com/privacy-policy |
|
|
Segment |
Reporting |
We use Segment to help measure how users interact with our websites. https://segment.com/legal/privacy/ |
|
|
Snapchat |
Reporting |
We use Snapchat to help measure how users interact with our websites. https://snap.com/privacy/privacy-policy |
|
|
Speedcurve Lux |
Reporting |
We use Speedcurve Lux to help measure how users interact with our websites. https://speedcurve.com/terms/ |
|
|
Taboola |
Reporting |
We use Taboola to help measure how users interact with our websites. https://www.taboola.com/policies/privacy-policy |
|
|
Tealium |
Reporting |
We use Tealium to help manage analytics vendors. https://tealium.com/privacy/ |
|
|
TikTok |
Reporting |
We use TikTok to help measure how users interact with our websites. https://www.tiktok.com/legal/privacy-policy?lang=en |
|
|
|
Reporting |
We use Twitter to help measure how users interact with our websites. https://twitter.com/en/privacy |
|
|
Yelp Audience Platform |
Reporting |
We use Yelp to help measure how users interact with our websites. https://terms.yelp.com/privacy/en_us/20200101_en_us/ |
|
|
Bing Ads |
Advertising |
We use Bing Ads to deliver targeted advertisements to individuals who visit our websites. https://privacy.microsoft.com/en-ca/privacystatement |
|
|
Drift |
Advertising |
We use Drift to help us with conversational marketing to customers while they visit our websites. https://www.drift.com/privacy-policy/ |
|
|
Facebook Custom Audiences |
Advertising |
We use Facebook Custom Audiences to deliver targeted advertisements to individuals who visit our websites. https://www.facebook.com/policy.php |
|
|
|
Advertising |
We use Google Ads to deliver targeted advertisements to individuals who visit our websites. https://policies.google.com/privacy |
|
|
Hubspot |
Advertising |
We use Hubspot to manage our relationships with our customers. https://legal.hubspot.com/privacy-policy |
|
|
Intercom |
Advertising |
We use Intercom to manage our relationships with our customers. https://www.intercom.com/terms-and-policies#privacy |
|
|
Marketo |
Advertising |
We use Marketo to manage our relationships with our customers. https://documents.marketo.com/legal/privacy/ |
|
|
Outbrain |
Advertising |
We use Outbrain to deliver targeted advertisements to individuals who visit our websites. https://www.outbrain.com/legal/privacy#privacy-policy |
|
|
Quora |
Advertising |
We use Quora to deliver targeted advertisements to individuals who visit our websites. https://www.quora.com/about/privacy |
|
|
|
Advertising |
We use Reddit Ads to deliver targeted advertisements to individuals who visit our websites. https://www.reddit.com/help/privacypolicy |
|
|
SourceKnowledge |
Advertising |
We use SourceKnowledge to deliver targeted advertisements to individuals who visit our websites. http://www.sourceknowledge.com/privacy |
|
|
Yahoo Japan Ads |
Advertising |
We use Yahoo Japan Ads to deliver targeted advertisements to individuals who visit our websites. https://about.yahoo.co.jp/common/terms/ |
|
4.8 Third party websites. Our website may, from time to time, contain 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.
5 PHOTOS, CONTENT AND PROMOTIONAL MATERIAL
5.1 This is information about you which you provide to us (whether through our website or otherwise), or images or recordings of you which you allow us (or someone on our behalf) to take (including at our premises or events), for publication or display. This may include reviews, comments, testimonials, photographs (including stock photos and advertising material) and videos.
5.2 We may display and publish this content (and, if relevant, attribute it to you) on our platforms as necessary for our legitimate interests in providing content and for promotional purposes (or, in some circumstances, because you have specifically consented to us doing this). This information is kept and published or displayed by us for as long as we consider it relevant for those purposes. You can ask us to remove or delete your content at any time (subject to any agreements about our right to use it) by contacting us. If we are displaying or publishing the information based on your consent, you have the right to withdraw that consent at any time.
6 PROFESSIONAL INFORMATION
6.1 If you work for one of our customers, suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you. This information may be collected directly from you, or provided by your organisation. Your organisation should have informed you that your information would be provided to us, and directed you to this policy. We use this as necessary for our legitimate interests in managing our relationship with your organisation. If we have a business relationship with you or your organisation, we may receive information about you from your organisation.
6.2 We keep this information for up to seven years after the end of our relationship with your organisation.
7 INFORMATION COLLECTED AT OUR PREMISES
7.1 CCTV. We may operate CCTV at our premises which may record you and your activities. We display notices to make it clear what areas are subject to surveillance. We only release footage following a warrant or formal request from law enforcement, or as necessary in relation to disputes. CCTV recordings may be kept for a period of up to 30 days (unless an incident occurs and it is necessary for us to keep recordings for longer to properly deal with it).
7.2 We use the information above as necessary for our legitimate interests in administering your visit, and ensuring site security and visitor safety.
8 APPLICATIONS, REFEREES AND EMERGENCY CONTACTS
8.1 We will collect and hold information on job applicants (including applications for work experience or internships), including information you provide to us in your application, or provided to us by recruitment agencies, as well as information on you from any referees you provide. We may also collect information about your professional history which you make available on LinkedIn, or which are on your employer's website.
8.2 We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights. Where you voluntarily provide us with special categories of data, such as information about your race, health or sexuality, we will store this as part of your application on the basis that you have decided to make it public to us for this purpose, and to ensure that our record of your application is accurate so we can comply with (and demonstrate our compliance with) our obligations under employment law.
8.3 We operate an equal opportunities monitoring process as part of some of our application rounds, in which you can provide details of your gender, age, marital status, health, ethnicity, and other relevant details as set out on our monitoring form. We use these forms and the information you provide as necessary for our legitimate interests in monitoring aggregate recruitment statistics and complying with our legal obligations regarding equal opportunities. The forms do not contain any information which allows us to directly identify you, and are detached from your application, stored separately, and only used to create aggregate statistics. Providing information in these forms is entirely voluntary, and the information you provide in those forms (or your decision not to provide any information) will not affect the handling of your application in any way. These forms are used to create aggregate statistical data (which you cannot be identified from) which is stored indefinitely.
8.4 If you are successful in your application, your information will be used and kept in accordance with our internal privacy notice. If you currently work for us, or used to work for us, you can request a copy of this from us. If you are not successful in your application, your information will be held for up to 6 months after the relevant round of recruitment has finished.
8.5 You must provide certain information (such as your name, contact details, professional and educational history) for us to consider your application fully. If you have not provided all of this information, we may contact you to ask for it. If you do not wish to provide this information, we may not be able to properly consider your application.
8.6 If you are listed as a referee by an applicant, we will hold your name, contact details, professional information about you (such as your employer and job title) and details of your relationship with the applicant. We will use this information as necessary for our legitimate interests in evaluating candidates and as necessary to exercise and perform our employment law obligations and rights. Your information will be kept alongside the applicant's information.
8.7 If you are listed as an emergency contact by someone who works for us, we will hold your name, contact details and details of your relationship with that member of staff. We will use this to contact you as necessary to carry out our obligations under employment law, to protect the vital interests of that member of staff, and for our legitimate interests in administering our relationship with that worker. Your information will be kept until it is updated by that member of staff, or we no longer need to contact them after they have stopped working for us.
9 LEGAL CLAIMS
Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. How long we keep this information for will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim.
10 WHY ELSE DO WE USE YOUR INFORMATION?
10.1 Common uses of your information. We will only use your personal information when the law allows us to do so. Although in limited circumstances we may use your information because you have specifically consented to it, we generally use your information in the ways set out in this notice because:
10.1.1 we need to perform a contract we have entered into with you.
10.1.2 we need to comply with a legal obligation.
10.1.3 it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.
10.1.4 we need to protect your interests (or someone else's interests) or where it is needed in the public interest (although these circumstances are likely to be rare).
10.2 Change of purpose. We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
11 INFORMATION WE RECEIVE FROM THIRD PARTIES
11.1 We may also receive information about you from the following sources:
11.1.1 Our service providers. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) who may provide us with information about you, to be used as set out in this privacy notice.
11.1.2 Businesses we have bought. If we have acquired another business, or substantially all of its assets, which originally held your information, we will hold and use the information you provided to them, or which they otherwise held about you, in accordance with this privacy notice. If we are reviewing whether to acquire a business, or substantially all of its assets, which holds your personal data (whether you are a customer or employee of that business or otherwise) we may receive limited personal data about you from that business or professional advisors involved in the transaction, as necessary for our legitimate interests in making decisions about that acquisition. If we do not acquire that business, any information we receive about you will be deleted as soon as practicable following the decision not to acquire.
11.1.3 Publicly available sources. If relevant as part of our relationship with you, we may obtain information from publicly available sources such as Companies House or LinkedIn.
12 SHARING YOUR INFORMATION
12.1 We never sell your data to third parties. But we may need to share your information with third parties, including third-party service providers and other entities in our group. Third parties are required to respect the security of your personal information and to treat it in accordance with the law.
12.2 Why might we share your personal information with third parties? We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
12.3 Which third-party service providers process your personal information? We may need to share your personal information with third-party service providers (including contractors and designated agents) so that they can carry out their services. We may use third-party service providers in relation to the following types of activity: legal advice, contract administration, order fulfilment, delivery, administration, IT services, payment processing. For example, we currently use Shopify, Zendesk, Omnisend, Aftership Returns, DPD, Royal Mail, Shop Pay, Paypal, Klarna and Amazon Pay, all of which will be provided with some personal information about you if relevant to your dealings with us.
In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice.
12.4 When might we share your personal information with other entities in the group? We may share your personal information with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, and for system maintenance support and hosting of data.
12.5 How secure is your information with third-party service providers and other entities in our group? All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. Where third parties process your personal information on our behalf as "data processors" they must do so only on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
12.6 What about other third parties? We may share your personal information with other third parties, for example with potential buyers and professional advisers in the context of the possible sale or restructuring of the business where necessary in connection with the purposes which your information was collected for. We may also need to share your personal information with a regulator or to otherwise comply with the law.
13 WHERE WE STORE YOUR INFORMATION
13.1 Our office headquarters and our main data centre is located in the UK. However, where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU. It may also be stored outside the UK and EU by our service providers (for instance, Shopify stores data in the USA and Canada, for more information see https://help.shopify.com/en/manual/your-account/privacy/GDPR/GDPR-merchants#international-data-transfers).
13.2 We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.
13.3 Some countries or organisations outside of the UK and the EU which we may transfer your information to will have an "adequacy decision" in place, meaning the EU considers them to have an adequate data protection regime in place. These are set out on the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
13.4 If we transfer data to countries or organisations outside of the UK and the EU which the EU does not consider to have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, model clauses approved by the EU or a data protection authority) are put in place where required. To obtain more details of these safeguards, please contact us.
14 DATA SECURITY
14.1 As well as the measures set out above in relation to sharing of your information, we have put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
14.2 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.
15 HOW LONG WILL WE KEEP YOUR INFORMATION FOR?
15.1 We have set out above indications of how long we generally keep your information. In some circumstances, it may be necessary to keep your information for longer than that in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
15.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
15.3 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
16 YOUR RIGHTS
16.1 Data protection law gives you a number of rights when it comes to personal information we hold about you. The key rights are set out below. More information about your rights can be obtained from the Information Commissioner's Office (ICO). Under certain circumstances, by law you have the right to:
16.1.1 Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
16.1.2 Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
16.1.3 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
16.1.4 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
16.1.5 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
16.1.6 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
16.1.7 Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.
16.1.8 Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another compelling legitimate interest in doing so.
16.1.9 Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.
16.2 No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
16.3 What we may need from you. We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. If we request any identification from you for this purpose, it is on the basis that it is necessary to comply with our legal obligations, and we will only keep and use this until your identity has been verified.
16.4 Timescale. Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.
17 CHANGES TO THIS PRIVACY NOTICE
Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Please check back frequently to see any updates or changes to our privacy notice.