Your privacy is very important to us. Accordingly, we have developed this policy in order for you to understand how we collect, use, communicate and make use of personal information. The following outlines our privacy policy.

When accessing our website we will learn certain information about you during your visit.

Similar to other commercial websites, our website utilises a standard technology called ‘cookies’ (see explanation below) and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.

Use of cookies

This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping baskets, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

IP addresses

IP addresses are used by your computer every time you are connected to the internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as “traffic data” so that data (such as the web pages you request) can be sent to you.

Email information

If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received online, mail and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site. For further information see the email policies below.

How do we use the information that you provide to us?

Broadly speaking, we use personal information for purposes of administering our business activities, providing customer service and making available other items and services to our customers and prospective customers.

We will not obtain personally-identifying information about you when you visit our site, unless you choose to provide such information to us, nor will such information be sold or otherwise transferred to unaffiliated third parties without the approval of the user at the time of collection.

We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights.

Email policies

We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and we will not provide your personal information to any third party individual, government agency, or company at any time unless strictly compelled to do so by law.

We will use your e-mail address solely to provide timely information about the services and products we offer.

We will maintain the information you send via e-mail in accordance with applicable federal law.

GDPR compliance

The EU General Data Protection Regulation (“GDPR”) comes into force across the European Union on 25th May 2018 and brings with it the most significant changes to data protection law in two decades. Founded on the fundamentals of privacy by design and a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.

The 21st century brings with it broad use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardise data protection laws and processing across the EU, affording individuals stronger, more consistent rights to access and control their personal information.

Our commitment
We are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognise the requirement and importance of updating and expanding this program to meet the demands of the GDPR and the Data Protection Act 1988.

We are dedicated to safeguarding the personal information under our remit and to developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation plans for the GDPR have been summarised in this statement and includes the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

How we are preparing for the GDPR

We already have a consistent level of data protection and security across our organisation, however it is our aim to be fully compliant with the GDPR by 25th May, 2018. Our preparation includes:

• Information audit – carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.
• Policies & procedures –Revising data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including: –
  
  
  • Data protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.
  • Data retention & erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
  • Data breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possibility. Our procedures are robust and have been disseminated to all employees, who are aware of the reporting lines and steps to follow.
  • International data transfers & third-party disclosures – wherewe store or transfer personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
  • Subject access request (SAR) – we have revised our SAR procedures to accommodate the revised 1-month timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.
• Legal basis for processing – we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we are also maintaining records of our processing activities, ensuring that our obligations under Article 30 of the GDPR are met.
• Privacy notice/policy – we have revisingour Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
• Obtaining consent – we are revisingour consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.
• Direct marketing – we have revisedthe wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
• Data protection impact assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
• Processor agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.
• Special categories data – where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.

Data subject rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information for an individual’s right to access any personal information we processes about them and to request information about: –

• What personal data we hold about them
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from them, information about the source
• The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
• The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
• The right to lodge a complaint or seek judicial remedy and who to contact in such instances

Information security & technical and organisational measures

We take the privacy and security of individuals and their personal information very seriously and are taking every reasonable measure and precaution to protect and secure the personal data that we process. We have dedicated information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures, including:

• SLL
• Password policy
• Encryptions

GDPR roles and employees

We have a designated Data Protection Officer (DPO). We understand that continuous employee awareness and understanding is vital to the continued compliance of the GDPR.

Choice/opt-out

Our site provides users the opportunity to opt-out of receiving communications from us and our partners by reading the unsubscribe instructions located at the bottom of any e-mail they receive from us at any time.

Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe link in the e-mail.

Use of external links

Our site may contain links to many other websites. We cannot guarantee the accuracy of information found at any linked site. Links to or from external sites not owned or controlled us do not constitute an endorsement by us, or any of our employees, of the sponsors of these sites or the products or
information presented therein.

By accessing this web site, you are agreeing to be bound by these web site Terms and Conditions of Use, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this web site are protected by applicable copyright and trade mark law.

Intellectual property rights

All copyrights, trademarks, patents and other intellectual property rights in and on our website and all content and software located on the site shall remain the sole property of us or our licencors. The use of our trademarks, content and intellectual property is forbidden without the express written consent of one of our directors as listed on Companies House at that time.

You must not:

• Republish material from our website without prior written consent.
• Sell or rent material from our website.
• Reproduce, duplicate, create, derivative copy or otherwise exploit material on our website for any purpose.
• Redistribute any content from our website, including onto another website.

Acceptable use

You agree to use our website only for lawful purposes, and in a way that does not infringe the rights of, restrict or inhibit anyone else’s use and enjoyment of the website. Prohibited behaviour includes harassing or causing distress or inconvenience to any other user, transmitting obscene or offensive content or disrupting the normal flow of dialogue within our website.

You must not use our website to send unsolicited commercial communications. You must not use the content on our website for any marketing related purpose without our express written consent.

Restricted access

We may in the future need to restrict access to parts (or all) of our website and reserve full rights to do so. If, at any point, we provide you with a username and password for you to access restricted areas of our website, you must ensure that both your username and password are kept confidential.

Use of testimonials

In accordance with the FTC guidelines concerning the use of endorsements and testimonials in advertising, please be aware of the following:

Testimonials that appear on this site are actually received via text, audio or video submission. They are individual experiences, reflecting real life experiences of those who have used our products and/or services in some way. They are individual results and results do vary. We do not claim that they are typical results. The testimonials are not necessarily representative of all of those who will use our products and/or services.

The testimonials displayed in any form on this site (text, audio, video or other) are reproduced verbatim, except for correction of grammatical or typing errors. Some may have been shortened. In other words, not the whole message received by the testimonial writer is displayed when it seems too lengthy or not the whole statement seems relevant for the general public.

We are not responsible for any of the opinions or comments posted on our website, nor is not a forum for testimonials, however we provide copies of testimonials as a means for customers to share their experiences with one another. To protect against abuse, all testimonials on our website appear after they have been reviewed by our management. We do not share our opinions, views or commentary of any testimonials on our website – the opinions are strictly the views of the testimonial source.

The testimonials are never intended to make claims that our products and/or services can be used to diagnose, treat, cure, mitigate or prevent any disease. Any such claims, implicit or explicit, in any shape or form, have not been clinically tested or evaluated.

How do we protect your information and secure information transmissions?

Email is not recognised as a secure medium of communication. For this reason, we request that you do not send private information to us by email. However, doing so is allowed, but at your own risk. Some of the information you may enter on our website may be transmitted securely via a secure medium known as Secure Sockets Layer, or SSL. Credit Card information and other sensitive information is never transmitted via email.

We may use software programs to create summary statistics, which are used for such purposes as assessing the number of visitors to the different sections of our site, what information is of most and least interest, determining technical design specifications, and identifying system performance or problem areas.

For site security purposes and to ensure that this service remains available to all users, we use software programs to monitor network traffic to identify unauthorised attempts to upload or change information, or otherwise cause damage.

Disclaimer and limitation of liability

We make no representations, warranties, or assurances as to the accuracy, currency or completeness of the content contained on this website or any sites linked to this site.

All the materials on this site are provided ‘as is’ without any express or implied warranty of any kind, including warranties of merchantability, non-infringement of intellectual property or fitness for any particular purpose. In no event shall we or our agents or associates be liable for any damages whatsoever (including, without limitation, damages for loss of profits, business interruption, loss of information, injury or death) arising out of the use of our materials or inability to use the materials, even if we have been advised of the possibility of such loss or damages.

Policy changes

We reserve the right to amend this privacy policy at any time with or without notice. However, please be assured that if the privacy policy changes in the future, we will not use the personal information you have submitted to us under this privacy policy in a manner that is materially inconsistent with this privacy policy, without your prior consent.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.