(a) We are committed to safeguarding the privacy of our website visitors. In this policy we explain how we will handle your personal data.
HOW WE USE YOUR PERSONAL DATA
(a) In this Section 2 we have set out:
(1) The general categories of personal data that we may process.
(2) In the case of personal data that we did not obtain directly from you, the source and specific categories of that data.
(3) The purposes for which we may process personal data.
(4) The legal bases of the processing.
(b) We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website.
(c) We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
(d) We may process information that you provide to us for subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
(e) We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
(f) We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
(g) In addition to the specific purposes for which we may process your personal data set out in this Section 2.0, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
(h) Please do not supply any other person's personal data to us unless we prompt you to do so.
PROVIDING YOUR PERSONAL DATA TO OTHERS
(a) In addition to the specific disclosures of personal data set out in this Section 3.0, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
(a) The hosting facilities for our website are situated in the Republic of Ireland and United Kingdom. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. [Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
(b) You acknowledge that personal data that you submit for publication through our website or services may be available via the internet around the world. We cannot prevent the use (or misuse) of such personal data by others.
RETAINING AND DELETING PERSONAL DATA
(a) This Section 5.0 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 data.
(b) Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
(c) We will retain and delete your personal data as follows:
(1) Your name, email address, mobile number will be retained for 12 months at the end of which period it will be deleted from our systems.
(d) In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(1) The period of retention of your name, email address, phone number will be determined based on your consent.
(e) Notwithstanding the other provisions of this Section 5.0, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
(a) We may update this policy from time to time by publishing a new version on our website.
(b) You should check this page occasionally to ensure you are happy with any changes to this policy.
(c) We may notify you of changes to this policy by email.
(a) We may withhold personal information that you request to the extent permitted by law.
(b) You may instruct us at any time not to process your personal information for marketing purposes.
(c) 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.
(d) We have summarised the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
(e) You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(1) 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).
(f) Your principal rights under data protection law are:
(1) The right to access.
(2) The right to rectification.
(3) The right to erasure.
(4) The right to restrict processing.
(5) The right to object to processing.
(6) The right to data portability.
(7) The right to complain to a supervisory authority.
(8) The right to withdraw consent.
(g) You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
(h) You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.
(i) In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
(j) In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person or for reasons of important public interest.
(k) You have the right to object to our processing of your personal data on grounds relating to your situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
(l) You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
(m) You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
(n) To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
(o) If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the Information Commissioner’s Office. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
(p) To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
(q) You may exercise any of your rights in relation to your personal data by writing to us, by email and telephone.
(a) 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.
(b) Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date, a session cookie on the other hand, will expire at the end of the user session when the web browser is closed.
(c) Cookies do not typically contain any information that personally identifies a user but personal information that we store about you may be linked to the information stored in and obtained from cookies.
COOKIES THAT WE USE
(1) This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the EU.
(2) Google will use this information for the purposes of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.
(4) By using the Inc Direct Ltd website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
(a) Most browsers allow you to refuse or accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(4) (Internet Explorer)
(b) Blocking all cookies will have a negative impact upon the usability of many websites.
(c) If you block cookies, you will not be able to use all the features on our website.
(a) This website is owned and operated by Inc Direct Ltd.
(b) We are registered in England and Wales under registration number 04684891, and our registered office is at: Inc Direct Ltd, 5 Dundee Way, Enfield, EN3 7SX
(c) Our principal place of business is at: Inc Direct Ltd, 5 Dundee Way, Enfield, EN3 7SX
You can contact us:
(1) By post using the postal address given above.
(2) Using our website contact form
(3) By telephone on the contact number published on our website.
(4) By email using the email address published on our website.
DATA PROTECTION OFFICER
• Richard Wright
• Inc Direct Ltd, 5 Dundee Way, Enfield, EN3 7SX
• Tel: 020 8344 6280
Name: Richard Wright
Position: Data Protection Officer
Date: 01 Feb 2018
Review Date: 31 Jan 2019