1.1We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
2.1This document was created using a template from SEQ Legal (http://www.seqlegal.com).
3.Collecting personal information
3.1We may collect, store and use the following kinds of personal information:
(a)information about your computer and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths);
(b)information that you provide to us when registering with our website (including [our email address);
(c)information that you provide when completing your profile on our website (including your name, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details);
(d)information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including [your name and email address);
(e)information that you provide to us when using the services on our website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);
(f)information relating to any purchases you make of our services or any other transactions that you enter into through our website (including your name, address, telephone number, email address);
(g)information that you post to our website for publication on the internet (including [your user name, your profile pictures and the content of your posts);
(h)information contained in or relating to any communication that you send to us or send through our website (including the communication content and metadata associated with the communication); and
(i)any other personal information that you choose to send to us.
3.2Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.
4.Using personal information
4.1Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.
4.2We may use your personal information to:
(a)administer our website and business;
(b)personalise our website for you;
(c)enable your use of the services available on our website;
(d)send you goods purchased through our website;
(e)supply to you services purchased through our website;
(f)send statements, invoices and payment reminders to you, and collect payments from you;
(g)send you non-marketing commercial communications;
(h)send you email notifications that you have specifically requested;
(i)send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(j)send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(k)provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(l)deal with enquiries and complaints made by or about you relating to our website;
(m)keep our website secure and prevent fraud; and
(n)verify compliance with the terms and conditions governing the use of our website (including monitoring private messages sent through our website private messaging service).
4.3If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us.
4.4Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
4.5We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.
5.Disclosing personal information
5.1We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
5.2We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.
5.3We may disclose your personal information:
(a)to the extent that we are required to do so by law;
(b)in connection with any ongoing or prospective legal proceedings;
(c)in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d)to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(e)to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
5.4Except as provided in this policy, we will not provide your personal information to third parties.
6.International data transfers
6.1Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
6.2Personal data shall not be transferred to a country or territory outside the European Union unless that country or territory ensures an adequate level of protection for the ‘rights and freedoms’ of data subjects in relation to the processing of personal data.
The transfer of personal data outside of the EU is prohibited unless one or more of the specified safeguards or exceptions apply;
- •Binding corporate rules
- •Model contract clauses in place
6.3Personal information that you publish on our website or submit for publication on our website may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
6.4You expressly agree to the transfers of personal information described in this Section 6.
7.Retaining personal information
7.1This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
7.2Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:
(a)to the extent that we are required to do so by law;
(b)if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c)in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
8.Security of personal information
8.1We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
8.2We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
9.1We may update this policy from time to time by publishing a new version on our website.
9.2You should check this page occasionally to ensure you are happy with any changes to this policy.
10.1You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
- •the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
10.2We may withhold personal information that you request to the extent permitted by law.
10.3You may instruct us at any time not to process your personal information for marketing purposes.
10.4In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
11.Third party websites
11.1Our website includes hyperlinks to, and details of, third party websites.
11.2We have no control over, and are not responsible for, the privacy policies and practices of third parties.
12.1Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. Google Analytics
13.1 We use a tool called ‘Google Analytics’ to collect information about the use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site.
13.2 We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information.
13.Data protection registration
13.1We are registered as a data controller with the UK Information Commissioner's Office.
We want to ensure that your use of our website is user friendly, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your computer or other device such as your mobile phone. These include small files known as “cookies”. We do not use these to identify you personally, or to hold any personal data.
These pieces of information are used to improve services for you through, for example:
Enabling a service to recognise your device so you don’t have to give the same information several times during one task
Recognising that you may already have provided a username and password so that you don’t need to keep repeating these for every web page requested
Measuring how many people are using services so they can be improved and there is enough capacity to ensure they are responsive
Cookies are small files, containing an ‘identifier’ given to your browser by a website which may be stored as text files (letters and numbers) in the cookie directory of your computer. Cookies are not programmes and cannot collect information from your computer. They do not damage your computer and are defined as ‘a piece of text stored on a computer by a web browser, a cookie can be used for authentication, storing site preferences, shopping cart contents, the identifier for a server-based session, or anything else that can be accomplished through storing text data’.
Our website may send cookie data to your browser, which may save it if your browser’s preferences allow it to do so. To protect your privacy your browser only returns a cookie to the website that sent you the cookie and does not send it to any other website. A website cannot access your cookie directory or information on your computer, instead relevant cookies are included by your browser within each request you make to the website. A website can only obtain cookie data that your browser sends to it. Cookies do not contain any information that personally identifies you. There are two types of cookie used:
Persistent cookies remain on your computer for a specified time and so are saved to your computer’s hard disk. We use persistent cookies to:
- •Identify that a registered user has returned
- •Securely remember your login User ID – if you have asked us to do so
- •Understand how you use our site and obtain information on website usage (as described above)
Session cookies are deleted when you close your browser and are not usually saved to your computer’s hard disk. We use session cookies to:
- •Identify that you have logged in to the site
- •Hold your search criteria while you are carrying out a search of the website
- •Collect information on website usage – as described above
You do not have to accept cookies and you can change the settings within your browser to accept all cookies, reject all cookies, reject cookies from certain websites, notify you if a site is requesting to set a cookie, and set various other options. You can also delete cookies already stored on your computer, although this may have a negative effect on the use of websites. Please see your browsers settings to do so.
Switching off cookies will still allow you to view the majority of content on our website. However, it will prevent you logging in and so accessing personalised information. It will also stop us remembering your login User ID, if you ask us to do so, and may restrict your use of our interactive tools and of some services available.
For further information or if you have any questions about the cookies we use or this policy please contact us.
Links to other websites
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
- whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to .
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.