PRIVACY POLICY
This Privacy Policy explains what happens to any personal data that you provide to us, or that we collect from you whilst you visit our site.
We do update this Policy from time to time so please do review this Policy regularly.
Information We Collect
In running and maintaining our website we may collect and process the following data about you:
- Information about your use of our site including details of your visits such as pages viewed and the resources that you access. Such information includes traffic data, location data and other communication data.
- Information provided voluntarily by you. For example, when you register for information or make a purchase.
- Information that you provide when you communicate with us by any means.
Use of Cookies
Cookies provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about your computer fin order to assist us in improving our website.
We may gather information about your general internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally. It is statistical data. This statistical data does not identify any personal details whatsoever
You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.
Our advertisers may also use cookies, over which we have no control. Such cookies (if used) would be downloaded once you click on advertisements on our website.
Use of Your Information
We use the information that we collect from you to provide our services to you. In addition to this we may use the information for one or more of the following purposes:
- To provide information to you that you request from us relating to our products or services.
- To provide information to you relating to other products that may be of interest to you. Such additional information will only be provided where you have consented to receive such information.
- To inform you of any changes to our website, services or goods and products.
If you have previously purchased goods or services from us we may provide to you details of similar goods or services, or other goods and services, that you may be interested in.
Where your consent has been provided in advance we may allow selected third parties to use your data to enable them to provide you with information regarding unrelated goods and services which we believe may interest you. Where such consent has been provided it can be withdrawn by you at any time.
Storing Your Personal Data
In operating our website it may become necessary to transfer data that we collect from you to locations outside of the European Union for processing and storing. By providing your personal data to us, you agree to this transfer, storing or processing. We do our upmost to ensure that all reasonable steps are taken to make sure that your data is treated stored securely.
Unfortunately the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically, Sending such information is entirely at your own risk.
Disclosing Your Information
We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below:
- In the event that we sell any or all of our business to the buyer.
- Where we are legally required by law to disclose your personal information.
- To further fraud protection and reduce the risk of fraud.
Third Party Links
On occasion we include links to third parties on this website. Where we provide a link it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any personal data.
Access to Information
In accordance with the Data Protection Act 1998 you have the right to access any information that we hold relating to you. Please note that we reserve the right to charge a fee of £10 to cover costs incurred by us in providing you with the information.
Contacting Us
Please do not hesitate to contact us regarding any matter relating to this Privacy Policy at [email address and postal address if considered appropriate].
Privacy Policy
We are committed to safeguarding the privacy of our website visitors; this policy sets out how we will treat your personal information.
[Our website uses cookies. [We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website. / By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.]
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
We [may] use [both] [“session” cookies] [and “persistent” cookies] on the website. [Session cookies will be deleted from your computer when you close your browser.] [Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.]
[We will use the session cookies to: keep track of you whilst you navigate the website; keep track of items in your shopping basket; prevent fraud and increase website security; and [other uses].] [We will use the persistent cookies to: enable our website to recognise you when you visit; keep track of your preferences in relation to your use of our website; and [other uses].]
We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html.
[We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using the DART cookie. You can view, delete or add interest categories associated with your browser using Google’s Ads Preference Manager, available at: http://www.google.com/ads/preferences/.
International data transfers
Information 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 privacy policy.
Information which you provide may be transferred to countries [(including [the United States], [Japan], [other countries])] which do not have data protection laws equivalent to those in force in the European Economic Area.
In addition, [personal information that you submit for publication on the website] will be published on the internet and may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
You expressly agree to such transfers of personal information.
Security of your personal information
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall-protected) servers.[16]
[All electronic transactions entered into via the website will be protected by encryption technology.]
You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
[You are responsible for keeping your password [and other login details] confidential. We will not ask you for your password (except when you log in to the website).]
Policy amendments
We may update this privacy policy from time to time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.
[We may also notify you of changes to our privacy policy by email.]
We may withhold such personal information to the extent permitted by law.
You may instruct us not to process your personal information for marketing purposes[, by sending an email to us]. In 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.
Third party websites
The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.
Updating information
Please let us know if the personal information which we hold about you needs to be corrected or updated.
Contact
If you have any questions about this privacy policy or our treatment of your personal information, please write to us by email to [email] or by post to [postal address].
The purpose of a website privacy policy is help website operators comply with data protection legislation. In the UK, that primarily means compliance with the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. Failure to comply with data protection legislation can lead to civil liability and criminal law penalties.
Our template privacy policy is designed for use by businesses based in the UK (although the UK data protection regime derives from EU law, there are differences in how that EU law has been implemented in the different member states of the EU). The template is designed for websites which collect standard kinds of non-sensitive personal data for standard kinds of use. It may be unsuitable for websites which collect sensitive personal data (such as information relating to a person’s health, sexuality, ethnicity or politics) or which collect personal information from children. It may be suitable, for example, for use with websites which act as online company brochures or online shops.
The template privacy policy will need to be edited before it is ready for use. Square brackets in the document indicate the sections which need or are likely to need to be edited. However, you should of course carefully review the whole document to ensure that it meets with your requirements. You should also regularly review your privacy policy to ensure that it remains up to date, both with respect to the law and to your business’s use of personal data. Please note that the use of a privacy policy does not exhaust your data protection obligations. If you are in any doubt regarding the preparation of your privacy policy or your data protection obligations generally, you should seek professional advice.
The privacy policy should be clearly and easily accessible to website visitors from the website home page and any page which collects personal data (eg “The personal information we collect on this page will be treated in accordance with our privacy policy”). In addition, key information about the use of personal data should be provided on the page where the data is collected, rather than in a separate document.
“Personal information”: for day-to-day purposes, it is best to assume that all information which relates to a living individual constitutes personal information. (We use “personal data” and “personal information” interchangeably in this template.)
The inclusion of this statement in your privacy policy will not in itself satisfy the requirements of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as regards consent to the use of cookies. Guidance concerning methods of obtaining such consent is included on the Information Commissioner’s website (http://www.ico.gov.uk).
You should list in this provision all of the different kinds of personal information which will be collected over or in relation to your website. We have suggested a number of common categories.
If your site does not use cookies, the paragraphs on cookies can be deleted.
The rules concerning cookies are set out in Regulation 6 of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended). Regulation 6 provides that:
“(1) Subject to paragraph (4), a person shall not store or gain access to information stored, in the terminal equipment of a subscriber or user unless the requirements of paragraph (2) are met.
(2) The requirements are that the subscriber or user of that terminal equipment—(a) is provided with clear and comprehensive information about the purposes of the storage of, or access to, that information; and (b) has given his or her consent.
(3) Where an electronic communications network is used by the same person to store or access information in the terminal equipment of a subscriber or user on more than one occasion, it is sufficient for the purposes of this regulation that the requirements of paragraph (2) are met in respect of the initial use.
(3A) For the purposes of paragraph (2), consent may be signified by a subscriber who amends or sets controls on the internet browser which the subscriber uses or by using another application or programme to signify consent.
(4) Paragraph (1) shall not apply to the technical storage of, or access to, information—(a) for the sole purpose of carrying out the transmission of a communication over an electronic communications network; or (b) where such storage or access is strictly necessary for the provision of an information society service requested by the subscriber or user.”
If you do not use Google Analytics, you should check whether your analytics system uses cookies and include an appropriate explanatory paragraph if it does.
If so, you should provide details. The following paragraphs give examples.
This text should be used if you publish Google AdSense interest-based advertisements on your website. Additional disclosures will be required if you have not opted out of third-party ad serving. For more information, see: https://www.google.com/adsense/support/bin/answer.py?hl=en&answer=100557.
As a general rule, where you plan to use personal information you have collected for the purpose of direct marketing, this should be made clear on the page where the information is collected, and you should ensure that this only happens if users opt in to the marketing (eg “Click here if you would like us to send you information by email about products which we think will interest you.”). There are, however, exceptions to this general rule. There are also rules about the content of direct marketing communications. If you are in any doubt about complying with your legal obligations in relation to direct marketing, you should seek professional advice.
You must list here all the uses to which you will (or may in future) put personal data. Again, we have suggested some common categories.
The relevant licence should be set out in the appropriate disclaimer/terms of use/terms of subscription etc document.
It is good practice to also say what you will not do with personal information (within reason).
You should insert details of any payment services provider(s) you use here. If you do not collect payments on your website, you can delete this section.
Give as much detail as possible about any such international transfers. You also need to be aware that the inclusion of this provision will not be sufficient to ensure that all international transfers of personal data are lawful. If in doubt, you should take professional advice on this point.
There is an obligation upon data controllers to store personal data securely. You should provide details of your security measures here.
Changes to the policy – in particular as to permissible uses of personal data – may not be retrospective. In other words, if you collect personal information on one basis, you cannot, simply by changing the terms of your policy, go on to legitimately use that information on a different basis.
You should include a postal address as well as an email address.
You should check whether you need to obtain a data protection registration. You can find out about this on the Information Commissioner’s website at http://www.ico.gov.uk.