This Privacy Policy sets out how we, [Chenai holistic home care], collect, store and use information about you when you use or interact with our website, [www.chhca.co.uk] (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from [insert the date when your privacy policy takes effect][1].
Contents[2]
Summary[6]
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
Our details
The data controller in respect of our website is [Chenai Holistic Home care] [(company registration number: [8827331])] of [London east uk business and technical park ,rainham road south ,Dagenham,rm10 7xs]. You can contact the data controller by writing to [Chenai Holistic Home Care ,London East uk Business and technical park Rainham road south Dagenham Rm10 7XSr] or sending an email to [info@chhca.co.uk].
[The data controller’s representative is [Melesia Facey]. You can contact the data controller’s representative by writing to [Chenai Holistic Home Care London East Uk Business and Technical Park Rainham Road South Dagenham Rm10 7XS] or sending an email to [Melesia@chhca.co.uk].][16] [The data protection officer for the data controller is [insert name of the data protection officer]. You can contact the data protection officer by writing to [insert correspondence address for the data protection officer] or sending an email to [insert email address].][17]
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
We use a [third party][18] server to host our website [called [insert name of server provider], the privacy policy of which is available here: [insert link to privacy policy]].[19] [Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as [the pages accessed,] [information requested,] [the date and time of the request,] [the source of your access to our website (e.g. the website or URL (link) which referred you to our website),] [and] [your browser version and operating system] [and] [insert any additional information your website’s server about an individual’s visit to your website.][20]
Our server is located in [insert country or countries outside the EEA in which your website server(s) is/are located] [and, accordingly, your information is transferred outside the European Economic Area (EEA). For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area]].[21]
Use of website server log information for IT security purposes
[[We do not access log data from our website server] OR [[We] AND/OR [our third party hosting provider]]] collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
[[Unless we are investigating suspicious or potential criminal activity,] [We/we] do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs].][22]
Legal basis for processing:compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing:our and [a third party’s] legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we [and our third party hosting provider] have a legitimate interest in using your information for the purposes of ensuring network and information security.
[Use of website server log information to analyse website use and improve our website
[We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit [and] [the operating system and browser used] [and] [insert any additional information collected by your website server log files].]
We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.]
Legal basis for processing:ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.][23]
[Cookies and [similar technologies]]
[We do not use cookies [or similar technologies] on our website.]
OR
[Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies [and similar technologies] on our website, including [[essential,] [functional,] [[analytical] [and] [targeting] cookies [and] [web beacons] [and] [insert any additional information gathering technologies you use on your website]]. For further information on how we use cookies, please see our cookies policy which is available here: [insert URL of cookies policy].][24]
You can reject some or all of the cookies we use on or via our website by changing your browser settings [or [non-essential cookies] by using our cookie control tool],[25] but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
Email
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
[We use a third party email provider to store emails you send us. Our third party email provider is [[insert name of third party email provider] OR [located in [insert country where your third party email provider is located]]. [Their privacy policy is available here: [insert link to your third party email provider’s privacy policy].][26] [Emails you send us will be stored [within OR outside] the European Economic Area on our [third party email provider’s] servers in [insert location (country) where your third party email provider stores your emails (usually where its servers are located)][27].For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.][28]
Contact form
When you contact us using our contact form, we collect [insert list of information which you collect about an individual when they contact you e.g. name, email address, IP address]. We also collect any other information you provide to us when you complete the contact form[, including any optional information, such as: [insert any optional information you collect via your website form e.g. phone number or company name]].[29]
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
[If you do not supply the optional information required by our contact form, [insert consequences of an individual not providing the optional information requested by your contact form (such as phone number) e.g. we will not be able to respond to your enquiry by phone.]][30]
[Messages you send us via our contact form will be stored [within OR outside] the European Economic Area on our [third party [hosting] OR [email] provider’s] servers in [insert location (country) where your third party provider stores your emails (usually where its servers are located)]. Our third party [email] or [hosting] provider is [[insert name of third party email provider] OR [located in [insert country where your third party email provider is located]]. [Their privacy policy is available here: [insert link to your third party email provider’s privacy policy].][31] [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][32] [We use a third party contact form provider to store messages you send us. Our contact form provider is [[insert name of third party email provider] OR [located in [insert country where your third party email provider is located]]]. [Their privacy policy is available here: [insert link to your third party email provider’s privacy policy]. Messages you send to us via our contact form will be stored [within OR outside] the European Economic Area on our contact form provider’s servers in [insert location (country) where your third party provider stores your emails (usually where its servers are located)]][33] [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][34]
[Phone[35]
When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.
[We [do not] record phone calls.][36]
Legal basis for processing:ourlegitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider[[, insert name of third party telephone service provider] OR [which is located in [insert location of third party telephone service provider].][37] [Their privacy policy is available here: [insert link to your third party email provider’s privacy policy].][38] [Information about your phone call will be stored by our third party telephone service provider [within OR outside] the European Economic Area. [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][39]
Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Information we collect when you interact with our website
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
[E-Newsletter
When you sign up for our e-newsletter [[on our website] or opt to receive [news, offers [and] [insert any additional types of information or content which your e-newsletter contains]] from us by [insert description of how individual signs up to receive your e-newsletter on your website e.g. by entering their name and email address and clicking subscribe or ticking a box at checkout indicating that they would like to receive your e-newsletter]], we collect [insert the information you collect from a user when they sign up for your e-newsletter e.g. name and email address]][40]
Legal basis for processing:yourconsent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
[[We use a [third party] service to send out our e-newsletter and administer our mailing list, [insert name of third party provider e.g. MailChimp or Dotmailer]. [Their privacy policy is available here: [insert link to third party’s privacy policy]].][41] [Information you submit to subscribe for our e-newsletter will be stored [[within OR outside]] the European Economic Area on our [third party mailing list provider’s] servers in [insert location (country) where your third party email provider stores your subscribers’ information (usually where its servers are located)].][42] [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][43]
[Use of web beacons [and similar technologies] in emails][44]
We use technologies such as [web beacons (small graphic files)] [and] [insert any other technologies used by your third party mailing list provider] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the [delivery rates,] [open rates] [and] [click through rates] [and] [insert any additional information you measure about user interaction with your emails][45] which our emails achieve.] [We will only use [web beacons] [and] [insert any other tracking technologies you use] in our emails if you have consented to us doing so.] [For more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available here: [insert link to cookies policy]][46] [For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: [insert link to privacy policy].][47]
[Registering on our website
When you register and create an account on our website, we collect the following information: [insert list of information which you collect about an individual when they contact you e.g. name, email address, IP address] and any other information you provide to us when you complete the registration form[, [including any optional information, such as [insert any optional information you collect via your website form e.g. phone number or company name]].[48]
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
[If you do not supply the optional information requested by our registration form, [insert consequences of individual not providing the optional information requested by your contact form (such as phone number) e.g. we will not be able to respond to your enquiry by phone.]] [Legal basis for processing:necessary to perform a contract [or to take steps at your request prior to entering into a contract](Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: creating an account on our website is necessary to allow you to access the goods and services you have purchased from us][49]
[Legal basis for processing:our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our website to [insert purpose e.g. to provide access to content] [and facilitate the running and operation of our business.]][50]
[Information you submit to us via the registration form on our website will be stored [[within] OR [outside]] the European Economic Area on our [third party hosting provider’s] servers in [insert location (country) where your third party provider stores your emails (usually where its servers are located)]. Our third party hosting provider is [[insert name of third party email provider] OR [located in [insert country where your third party email provider is located]]. [Their privacy policy is available here: [insert link to your third party email provider’s privacy policy].][51] [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][52]
Information we collect when you place an order [on our website]
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Information collected when you place an order
Mandatory information
When you place an order for goods or services on our website, we collect [[your name,] [email address,] [billing address,] [shipping address,] [company name (if applicable),] [VAT number (if applicable),] [and] [insert any other mandatory information you collect from customers at checkout].]
If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing:necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.[53] [Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions][54]
Optional information
We also collect optional information from you, such as [your phone number,] [information about how you heard about us] [and] [insert any additional optional information which you collect from customers at checkout]. [We also ask you if you would like to receive marketing communications [[from us] AND/OR third parties]]. For further information, see ‘Marketing communications’ in this section below.] [If you do not supply the optional information requested at checkout, [insert consequences of individual not providing the optional information requested by your contact form (such as phone number) e.g. we will not be able to contact you by phone.] [Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests:[insert the legitimate interest you have in collecting any optional information at your website checkout e.g. finding out how a customer heard about you to improve your business’ advertising methods or to be able to contact the customer by phone where (if necessary) in relation to their order][55]
[AND/OR]
Legitimate interests:you consent to us processing any optional information you provide by submitting that information to us.][56]
Processing your payment
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use [[a third party payment processor,] OR [third party payment processors, including] [insert name(s) of third party payment processors used on your website e.g. PayPal or Stripe]]. Your payment will be processed by [[insert name of third party payment processor you use] OR [the third party payment processor you choose to process your payment] [via a payment gateway]].
[[insert name of third party payment processor you use] OR [the third party payment processor you choose to process your payment]] collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access [its / their privacy policies] via the following link(s): [insert links to the privacy policies of your payment processor(s)].[57]
[insert name of third party payment processor you use] is located in [insert country where you payment processor is located]. Information relating to the processing of your payment is stored [[within OR outside]] the European Economic Area on our [third party payment processor’s] servers in [insert location (country) where your third party provider stores your emails (usually where its servers are located)].
[For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][58]
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.
Marketing communications
At checkout you will have the option of receiving marketing communications from us.
[Our similar goods and services[59]
You can opt-out from receiving marketing communications in relation to our goods and which are similar to those which you purchase from us, by [insert method by which consumer may opt out from receiving communications e.g. by ticking a box to opt out or by unticking a pre-ticked box].
We will send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.
Legitimate interests: direct marketing and advertising our products and services.]
[We use a third party service to administer our mailing list, [insert name of third party provider e.g. MailChimp or Dotmailer].][60] [Information you submit to subscribe for our e-newsletter will be stored [[within OR outside]] the European Economic Area on our [third party mailing list provider’s] servers in [insert location (country) where your third party email provider stores your subscribers’ information (usually where its servers are located)].][61] [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][62]
[Use of web beacons [and similar technologies] in emails][63]
We use technologies such as [web beacons (small graphic files)] [and] [insert any other technologies used by your third party mailing list provider] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the [delivery rates,] [open rates] [and] [click through rates] [and] [insert any additional information you measure about user interaction with your emails][64] which our emails achieve.] [We will only use [web beacons] [and] [insert any other tracking technologies you use] in our emails if you have consented to us doing so.] [For more information on how we use web beacons in our emails, see our cookies policy which is available here: [insert link to cookies policy]][65] [For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: [insert link to privacy policy].][66]
[Our goods and services][67]
You can opt in to receiving marketing communications from us in relation to our goods and services [by [email,] [text message,] [phone,] [and/or] [post]] by [insert method by which an individual can opt in to receiving communications e.g. by ticking a box indicating that you would like to receive such communications].[68]
We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.
Legal basis for processing:consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.
[We use a third party service to administer our mailing list, [insert name of third party provider e.g. MailChimp or Dotmailer].][69] [Information you submit to subscribe for our e-newsletter will be stored [[within OR outside]] the European Economic Area on our [third party mailing list provider’s] servers in [insert location (country) where your third party email provider stores your subscribers’ information (usually where its servers are located)].][70] [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][71]
[Use of web beacons [and similar technologies] in emails][72]
We use technologies such as [web beacons (small graphic files)] [and] [insert any other technologies used by your third party mailing list provider] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the [delivery rates,] [open rates] [and] [click through rates] [and] [insert any additional information you measure about user interaction with your emails][73] which our emails achieve.] [We will only use [web beacons] [and] [insert any other tracking technologies you use] in our emails if you have consented to us doing so.] [For more information on how we use web beacons in our emails, see our cookies policy which is available here: [insert link to cookies policy]][74] [For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: [insert link to privacy policy].][75]
[Third party goods and services][76] [In addition to receiving information about our products and services] [You/you] can opt in to receiving marketing communications from us in relation third party goods and services [by [email,] [text message,] [phone,] [and/or] [post]] by [insert method by which an individual can opt in to receiving communications e.g. by ticking a box indicating that you would like to receive such communications].[77]
Consent: you give your consent to us sending you information about third party goods and services by signing up to receive such information in accordance with the steps described above.
[We use a third party service to administer our mailing list, [insert name of third party provider e.g. MailChimp or Dotmailer].][78] [Information you submit to subscribe for our e-newsletter will be stored [[within OR outside]] the European Economic Area on our [third party mailing list provider’s] servers in [insert location (country) where your third party email provider stores your subscribers’ information (usually where its servers are located)].][79] [For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.][80]
[Use of web beacons [and similar technologies] in emails][81]
We use technologies such as [web beacons (small graphic files)] [and] [insert any other technologies used by your third party mailing list provider] in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the [delivery rates,] [open rates] [and] [click through rates] [and] [insert any additional information you measure about user interaction with your emails][82] which our emails achieve.] [We will only use [web beacons] [and] [insert any other tracking technologies you use] in our emails if you have consented to us doing so.] [For more information on how we use web beacons in our emails, see our cookies policy which is available here: [insert link to cookies policy]][83] [For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here: [insert link to privacy policy].][84]
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.
Information received from third parties
[Generally,] we [do/do not] receive information about you from third parties. The third parties from which we receive information about you will generally include [insert names of businesses who you are likely to receive information about individuals from e.g. group companies, affiliates or business partners].
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Legal basis for processing:necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
Legal basis for processing:our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
Where we receive information about you in error
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Information obtained by us from third parties
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as [[the electoral register,] [Companies House,] [online customer databases,] [business directories], [media publications,] [social media,] [and] websites (including your own website if you have one) [and] [insert any additional public sources from which you collect or expect that you collect information about an individual]].[85]
In certain circumstances will also obtain information about you from private sources, both EU and non-EU, such as [insert any private sources from which you collect or expect that you collect information about an individual e.g. data brokers]
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.
For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.
[Legal basis for processing:consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: we may obtain information from third parties, such as data brokers, where you have consented to them sharing information with us by [insert method by which individual consent e.g. ticking a box stating that you would like your information to be share with us.]][86] [Our use of automated decision-making and profiling[87]
We use [[automated decision making] [and] [profiling]] on our website. [We do not consider that this has any legal effect on you or similarly significantly affects you.][88] [You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.]
You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: [insert link to cookies policy]
[Automated decision making[89]
Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.
[Use of automated decision making for [display] advertising][90] [We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here: [insert link to cookies policy]
Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.
Significance and envisaged consequences: cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.
How to object: you can block these cookies by [using the cookies control management tool on your site (if you use one)][91] [insert method of blocking cookies e.g. blocking third party cookies using browser settings, or insert specific method e.g. for Google DoubleClick, by opting out of seeing personalised ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB]. For further information, please see our cookies policy: [insert link to your cookies policy] [Insert use of automated decision making][92] [[We use automated decision making for [insert purposes for which you use automated decision making] OR [we do not use automated decision making].]
Logic involved: [insert the logic involved in you used automated decision making e.g. to increase efficiencies]
Significance and envisaged consequences: [insert the significance and envisaged consequences for the individual of your use of automated decision making]
How to object: [insert description of how individual may object i.e. stop the processing of their personal information for automated decision making purposes] [Legal basis for processing:[insert legal basis for processing e.g. your legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).]] [Legitimate interest: [describe your legitimate interest in the automated decision making activity (if you are relying on your legitimate interests as your legal basis for processing]]
Profiling
Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
[Use of profiling for web analytics
[Our web analytics service, [insert name of web analytics service e.g. Google Analytics] uses collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on) [and] [insert any other behaviours which are analysed when a user visits your website] We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy ([insert link to cookies policy]). [Information collected about you, once collected is anonymised and stored on an aggregate basis.][93]
Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.
Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by [insert method of opting out from analytical cookies used on your website]) and your location will be analysed based on your IP address. [We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.]] [Legal basis for processing:[insert legal basis for processing e.g. your legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).]] [Legitimate interest: [describe your legitimate interest in the relevant profiling activity (if you are relying on your legitimate interests as your legal basis for processing]]
[Use of profiling in marketing emails]
[We use [[web beacons] AND/OR [insert other technologies]] in our marketing emails to analyse who opens our emails [and what actions they take (for example, what they click on)]. We will only process information from [[web beacons] AND/OR [insert other technologies you use]] if you have consented to their use in accordance with our cookies policy ([insert link to cookies policy]).
Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.
Significance and envisaged consequences: your behaviour when you open our emails will be tracked using [small gif files (web beacons)] [and] [insert any other technologies used]], including [open rates], [click through rates], [and] [insert any other information you measure about individuals in your marketing emails].
How to object: [insert method of allowing an individual to object to your use of web beacons and similar technologies e.g. contact you][94]
Legal basis for processing:legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: [analysing the level of engagement and effectiveness of our marketing emails and content] [Insert use of profiling][95] [[We use profiling for: [insert purposes for which you use profiling]]
Logic involved: [insert the logic involved in your use of profiling e.g. to increase efficiencies]
Significance and envisaged consequences: [insert the significance and envisaged consequences for the individual of your use of profiling]
How to object: [insert description of how individual may object i.e. stop the processing of their personal information for profiling purposes] [Legal basis for processing:[insert legal basis for processing e.g. your legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).]] [Legitimate interest: [describe your legitimate interest in the relevant profiling activity (if you are relying on your legitimate interests as your legal basis for processing]]
Disclosure and additional uses of your information
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business [and who process your information for us on our behalf].[96] These include the following:[97]
[Our third party service providers are located in [insert country in which your third party service providers are located e.g. England]] OR [Apart from [insert types of service providers], which are located in [insert locations of service providers e.g. the US], our service providers are located in [insert location of service providers e.g. England].[98]
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
[We do not display the identities of [all of] our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly [via our contact form] or [by email] and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).][99]
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing:necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.
Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as [Google Inc.][, [and] insert any other third parties to whom information is provided]. [Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/][100]
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout
Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.]
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our [accountants,][advisors,][affiliates,][business partners,][independent contractors,][and][insurers,][and][insert any additional specific categories of individuals or entities with whom or which you share an individual’s personal data for managing your business]. Further information on each of these third parties is set out below.[101]
Legitimate interest: running and managing our business efficiently.
[Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.] [Our accountants are [insert name of accountants]. Their privacy policy is available here: [insert link to privacy policy]] OR [Our accountants are located in [insert location of your accountants e.g. England].]
[Advisors
Occasionally, we obtain advice from advisors, such as [accountants,] [financial advisors,] [lawyers] [and] [public relations professionals] [and] [insert any additional advisors you may share an individual’s information with]. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.] [[Our advisors are [insert names of advisors]]. Their privacy policy is available here: [insert link to privacy policy] OR [Our advisors are located in [insert location of your advisors e.g. England].]]
[Affiliates
Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Our affiliates can be in [insert the types of business or individual your affiliates are by industry, sector and sub-sector]. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.] [[Our affiliates are [[insert names of affiliates] OR [industry, sector and sub-sector your affiliates are based in]. Their privacy policy is available here: [insert link to privacy policy]] OR [[Our affiliates are located in [insert location of your advisors e.g. England].]]
[Business partners
Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.] [Our business partners are [[insert names of business partners] OR [industry, sector and sub-sector your business partners are based in]]. Their privacy policy is available here: [insert link to privacy policy]] OR [Our business partners are located in [insert location of your advisors e.g. England].]
[Independent contractors
[Occasionally,] we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.] [[Our independent contractors are [[insert names of independent contractors] OR [industry, sector and sub-sector your independent contractors are in]]. Their privacy policy is available here: [insert link to privacy policy]] OR [Our independent contractors are located in [insert location of your advisors e.g. England].]]
[Insurers
We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.] [[Our insurers are [insert name of insurers]]. Their privacy policy is available here: [insert link to privacy policy] OR [Our insurers are located in [insert location of your advisors e.g. England].]]
[Insert type of third party recipient of information]
[insert description of circumstances in which you will share an individual’s information with that third party recipient] [[Our [insert name of third party recipient(s) is/are [insert name(s) of third party/third parties]]. OR [Our [insert name of third party recipient] is located in [insert location of third party recipient e.g. England].]]
[Sharing your information within our business’ group of companies, including [insert details of other entities in your corporate group with whom you share personal information] for internal administrative purposes, including client, customer and employee information.[102]
Legitimate interest:running and managing our business effectively.
AND/OR
Legal basis for processing:necessary to perform a contract [or to take steps at your request prior to entering into a contract](Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract:we need to share your information with other companies in order to be able to meet our contractual obligations to you [or to take steps at your request prior to entering a contract.], for example because of the services or information you have requested.
[We do not display the identities of [all of] the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly [via our contact form] or [by email] and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).][103]
Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.
Legitimate interest(s):sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.
Disclosure and use of your information for legal reasons
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one [or to the National Crime Agency in connection with suspected or potential money laundering matters][104].
Legal basis for processing:compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s):legal obligations to disclose information which are part of the laws of [England and Wales][105] or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).
Legal basis for processing:our legitimate interests(Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Retention periods[106]
[Server log information: we retain information on our server logs for [insert period for which you retain information from server logs.]
[Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.][107]
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether [[by email] [or via our contact form] [or by phone]], we will retain your information for as long as it takes to respond to and resolve your enquiry, and for [[●] further month(s)],[108] after which point we will delete your information.
[E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.]
[insert additional category of data stored]: [insert details of the specific retention period for additional category of data][109]
Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
How we secure your information[111]
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.[114]
Transfers of your information outside the European Economic Area[115] [All of your information is stored in the following European Economic Area (EEA) countries [country/countries]: [insert EEA countries in which you store individuals’ information].
Other than to comply with any legal obligations to which we are subject (compliance with a court order, for example), we do not intend to transfer your information outside the EEA or to an international organisation. In the unlikely event that we are required to transfer your information outside the EEA (or to an international organisation) for such a purpose, we will ensure appropriate safeguards and protections are in place.
[Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.][116]
[Server log information
[Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our [third party hosting company[, insert name of third party hosting company]. You can access their privacy policy here: [insert link to privacy policy].]
[Country of storage: [insert the country or countries where the relevant servers which collect information in relation to your website are located and where the information is stored]. This country [is/is not] subject to an adequacy decision by the European Commission.][117]
Safeguard(s) used: [our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert other safeguard which your third party hosting company uses to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].[118]
[Contact form
[Information you submit to us via our contact form is transferred outside the EEA and stored on our third party [[hosting] OR [email] OR [insert entity which stores information submitted by your contact form] provider’s servers. Our [insert type of third party provider (hosting provider, email provider)] is [insert name of third party provider]. You can access their privacy policy here: [insert link to privacy policy].]
[Country of storage: [insert the country or countries where the relevant servers which collect information in relation to your website are located and where the information is stored]. This country [is/is not] subject to an adequacy decision by the European Commission.][119]
Safeguard(s) used: [our [[third party hosting provider] OR [third party email provider] OR [insert entity which stores information submitted by your contact form]] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert other safeguard which your third party hosting company uses to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].[120]
[Email
[Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. Our third party email provider is: [insert name of third party email provider]. You can access their privacy policy here: [insert link to privacy policy].]
[Country of storage: [insert the country or countries where the relevant servers which collect information in relation to your website are located and where the information is stored]. This country [is/is not] subject to an adequacy decision by the European Commission.][121]
Safeguard(s) used: [our [third party email provider] OR [insert entity which stores information submitted by your contact form]] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert other safeguard which your third party hosting company uses to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].[122]
[Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is: [insert name of third party mailing list provider]. You can access their privacy policy here: [insert link to privacy policy].]
[Country of storage: [insert the country or countries where the relevant servers which collect information in relation to your website are located and where the information is stored]. This country [is/is not] subject to an adequacy decision by the European Commission.][123]
Safeguard(s) used: [our [third party mailing list provider] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert safeguards used to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].[124]
[Google Analytics
[Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
[Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.][125]
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
[Insert additional data collection method or use e.g. information outside the EEA by payment processors][126] [Information you submit to us by [insert method individual uses to submit information to you] is transferred outside the EEA] and stored on our [insert type of third party] servers. Our [insert type of third party provider e.g. email provider] is: [insert name of third party provider]. You can access their privacy policy here: [insert link to privacy policy].]
[Country of storage: [insert the country or countries where the relevant servers which collect information in relation to your website are located and where the information is stored]. This country [is/is not] subject to an adequacy decision by the European Commission.][127]
Safeguard(s) used: [our [insert third party provider for data collection and use] has self-certified its compliance with the EU-U.S. Privacy Shield] OR [insert safeguards used to transfer information to a country which is outside the EEA (see Appendix 1 for the full list)] [which is available [here: [insert link to the safeguards used] OR [insert means of obtaining a copy of the safeguard]].[128]
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to [insert address] [or sending an email to [insert email address]]:
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to [insert address] [or sending an email to [insert email address]]:
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: [insert link to your cookies policy]
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
[We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.]
[insert details of the sensitive personal information you collect about individuals, how you collect it, what you use it for and the legal basis on which you process it.][131]
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to [insert email address].
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org
[We respond to Do Not Track browser settings or signals by [insert details of how you recognise and respond to Do Not Track browser settings]] OR [[At this time, we do not respond to Do Not Track browser settings or signals. [In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.] For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: [insert link to cookies policy]][132]
Copyright, credit and logo
This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit https://gdprprivacypolicy.org
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.
Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.
Appendix 1
Safeguards for overseas transfers
NOTE TO USER: THIS APPENDIX IS FOR REFERENCE AND ASSISTANCE WITH COMPLETING YOUR PRIVACY POLICY AND SHOULD BE DELETED PRIOR TO YOU UPLOADING YOUR PRIVACY POLICY TO YOUR WEBSITE
