Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|means an account required to access and/or use certain areas and features of Our Site;
|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 Site are set out in Part 14, below; and
|means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
Information About Us
Our Site is owned and operated by FurtherMore Marketing a Limited company registered in England under company number 09325423. Registered address: Bankside 300 Peachman Way, Broadland Business Park, Norwich, Norfolk, United Kingdom, NR7 0LB VAT number: 201 8222 59 Data Protection Officer: James Humphreys-White. Email address: firstname.lastname@example.org Telephone number: 01603 273131 Postal address: FurtherMore Marketing Ltd, Klyne Business Aviation Centre, Norwich Airport, Norwich, NR6 6JT Representative: Lexi Brackpool Email address: email@example.com Telephone number: 01603 273131 Postal address: FurtherMore Marketing Ltd, Klyne Business Aviation Centre, Norwich Airport, Norwich, NR6 6JT
What Does This Policy Cover?
What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to ask us to delete or otherwise dispose of any of your personal data that we use. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data. Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau. If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first, using the details in Part 15.
What Data Do You Collect and How?
|How We Collect the Data
|Identity Information including name, title, date of birth, gender
|Via Our WordPress based Site, over the telephone or via email or social media interaction and marketing
|Contact information including address, email address, telephone numbers
|Via Our WordPress based site, over the telephone or via email or social media interaction and marketing
|Business information including business name, job title, profession, address, email address, telephone numbers
|Via Our WordPress based site, over the telephone or via email or social media interaction and marketing
|Payment information including card details, bank account numbers, CVV codes
|Via Our WordPress based site, over the telephone, email, payment processing partners and servers,
|Technical information including IP address, browser type and version, country, operating system
|Via Our WordPress based site and servers
|Data from third parties
|Social media platform and insights tools
How Do You Use My Personal Data?
Under the Data Protection Legislation, we must always have a lawful basis for using personal data which comprises legitimate interests in securing sales, sending quotations and further information or communications, processing payments, re-marketing. Examples of how we use your personal data include (a) registering you on our website, (b) providing and managing your Account (if any), (c) providing and managing your access to our website, (d) personalising and improving your experience on our website, (e) administering Our Site and our business, (f) communicating with you, (g) Supplying our services and products to you, (h) managing payments for our services and products, (i) supplying you with information that you have opted in to receive such as newsletters (j) re-marketing via social media campaigns. 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 Data Protection Legislation 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 website 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 will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15. If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so. In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
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.
How and Where Do You Store or Transfer My Personal Data?
We will store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law. We may store or transfer some or all of your personal data in countries that are not part of the EEA. 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 Data Protection Legislation as follows: We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission. Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms 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:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.
Do You Share My Personal Data?
Subject to part 9, we will not share any of your personal data with any third parties for any purposes, subject to the following exception[s]. If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
How Can I Control My Personal Data?
- In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, we aim to give you strong controls on use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Can I Withhold Information?
How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We aim to respond to your subject access request within 14 calendar days and, in any case, no more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
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 (for the attention of Alexis Brackpool): Email address: firstname.lastname@example.org Telephone number: 01603 273131 Postal address: FurtherMore Marketing Ltd, Klyne Business Aviation Centre, Norwich Airport, Norwich, NR6 6JT