1.1 We are committed to safeguarding the privacy of our website visitors and
service users.
1.2 This policy applies where we are acting as a data controller with respect
to the personal data of our website visitors and service users; in other words,
where we determine the purposes and means of the processing of that personal
data.
1.3 Our website incorporates privacy controls which affect how we will process
your personal data. By using the privacy controls, you can specify whether you
would like to receive direct marketing communications and limit the publication
of your information.
1.4 In this policy, “we”, “us” and “our” refer to
our website. For more information about us, see Section 19.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the
source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 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. The source of the usage data
is our analytics tracking system. This usage data may be processed for the
purposes of analysing the use of the website and services. The legal basis for
this processing is consent OR our legitimate interests, namely monitoring and
improving our website and services.
2.3 We may process your account data “account data”. The account data
may include your name and email address. The source of the account data is you
or your employer. The account data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and communicating
with you. The legal basis for this processing is consent OR our legitimate interests,
namely the proper administration of our website and business OR the performance
of a contract between you and us and/or taking steps, at your request, to enter
into such a contract.
2.4 We may process your information included in your personal profile on our
website “profile data”. The profile data may include your name,
address, telephone number, email address, profile pictures, gender, date of
birth, relationship status, interests and hobbies, educational details and
employment details. The profile data may be processed for the purposes of
enabling and monitoring your use of our website and services. The legal basis
for this processing is consent OR our legitimate interests, namely the proper
administration of our website and business OR the performance of a contract
between you and us and/or taking steps, at your request, to enter into such a
contract.
2.5 We may process your personal data that are provided in the course of the
use of our services “service data”. The service data may include your
name, email, postal address and telephone number. The source of the service
data is you or your employer. The service data may be processed for the
purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is consent OR our
legitimate interests, namely the proper administration of our website and
business OR the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
2.6 We may process information that you post for publication on our website or
through our services “publication data”. The publication data may be
processed for the purposes of enabling such publication and administering our
website and services. The legal basis for this processing is consent OR our
legitimate interests, namely the proper administration of our website and
business OR the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
2.7 We may process information contained in any enquiry you submit to us
regarding goods and/or services “enquiry data”. The enquiry data may
be processed for the purposes of offering, marketing and selling relevant goods
and/or services to you. The legal basis for this processing is consent.
2.8 We may process information relating to transactions, including purchases of
goods and services that you enter into with us and/or through our website
“transaction data”. The transaction data may include your contact
details, your card details and the transaction details. The transaction data
may be processed for the purpose of supplying the purchased goods and services
and keeping proper records of those transactions. The legal basis for this
processing is the performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract and our legitimate
interests, namely our interest in the proper administration of our website and
business.
2.9 We may process information that you provide to us for the purpose of
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 OR the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract.
2.10 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.
2.11 We may process your details in the form of name, email, postal address and
telephone number. The source of this data is contact forms. This data may be
processed and used for client communication and marketing purposes. The legal
basis for this processing is consent.
2.12 We may process any of your personal data identified in 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.
2.13 We may process any of your personal data identified in this policy where
necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, or obtaining professional advice. The legal basis for this
processing is our legitimate interests, namely the proper protection of our
business against risks.
2.14 In addition to the specific purposes for which we may process your
personal data set out in this Section 2, 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 in order to protect your vital interests or the
vital interests of another natural person.
2.15 Please do not supply any other person’s personal data to us, unless we
prompt you to do so.
3. Automated decision-making
3.1 We will use your personal data for the purposes of automated
decision-making in relation to communication within contracts and marketing
purposes.
3.2 The significance and possible consequences of this automated
decision-making are that you may be contacted using the details you have
supplied.
4. Providing your personal data to others
4.1 We may disclose your personal data 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, and on the
legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional
advisers insofar as reasonably necessary for the purposes of obtaining or maintaining
insurance coverage, managing risks, obtaining professional advice, or the
establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
4.3 We reserve the right to share your data with our partners and subsidiaries.
4.4 We may disclose your enquiry data to one or more of those selected third
party suppliers of goods and services identified on our website for the purpose
of enabling them to contact you so that they can offer, market and sell to you
relevant goods and/or services. Each such third party will act as a data
controller in relation to the enquiry data that we supply to it; and upon
contacting you, each such third party will supply to you a copy of its own
privacy policy, which will govern that third party’s use of your personal data.
4.5 In addition to the specific disclosures of personal data set out in this
Section 4, we may disclose your personal data where such disclosure is
necessary for compliance with a legal obligation to which we are subject, or in
order to protect your vital interests or the vital interests of another natural
person. We may also disclose your personal data where such disclosure is
necessary for the establishment, exercise or defence of legal claims, whether
in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which
your personal data may be transferred to countries outside the European
Economic Area (EEA).
5.2 We and our other group companies have offices and facilities in London,
Sydney, Toronto, Istanbul, Singapore, Hong Kong & China and Los Angeles.
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.
5.2 The hosting facilities for our website are situated in the 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, a copy of which you can obtain from
https://ec.europa.eu/commission/index_en.
5.3 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,
a copy of which can be obtained from https://ec.europa.eu/commission/index_en.
5.4 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.
6. Retaining and deleting personal data
6.1 This Section 6 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.
6.2 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.
6.3 We will retain your personal data as follows:
(a) Your name, email address, postal address and telephone number will be
retained for a minimum period of 6 years.
6.4 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:
(a) the period of retention of personal data will be determined by the
possibility that you are still a client.
6.5 Notwithstanding the other provisions of this Section 6, we may retain your
personal data where such retention is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests
or the vital interests of another natural person.
7. Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure
your personal data and to prevent the loss, misuse or alteration of your
personal data.
7.2 We will store all your personal data on secure servers, personal computers
and mobile devices, and in secure manual record-keeping systems.
7.3 The following personal data will be stored by us in encrypted form: your
name, contact information, password(s).
7.4 Data relating to your enquiries and financial transactions that is sent
from your web browser to our web server, or from our web server to your web
browser, will be protected using encryption technology.
7.5 You acknowledge that the transmission of unencrypted (or inadequately
encrypted) data over the internet is inherently insecure, and we cannot
guarantee the security of data sent over the internet.
7.6 You should ensure that your password is not susceptible to being guessed,
whether by a person or a computer program. You are responsible for keeping the
password you use for accessing our website confidential and we will not ask you
for your password (except when you log in to our website).
8. Amendments
8.1 We may update this policy from time to time by publishing a new version on
our website.
8.2 You should check this page occasionally to ensure you are happy with any
changes to this policy.
8.3 We may notify you of changes to this policy by email.
9. Your rights
9.1 You may instruct us to provide you with any personal information we hold
about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at GBP 30); and
(b) the supply of appropriate evidence of your identity (for this purpose, we
will usually accept a photocopy of your passport certified by a solicitor/driving
licence or bank plus an original copy of a utility bill showing your current
address).
9.2 We may withhold personal information that you request to the extent
permitted by law.
9.3 You may instruct us at any time not to process your personal information
for marketing purposes.
9.4 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. OR 9. Your rights
9.1 In this Section 9, we have summarised the rights that you have under data
protection law. Some of the rights are complex, and not all of 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.
9.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
9.3 You have the right to confirmation as to whether or not 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.
See 9.1a for details.
9.4 You have the right to have any inaccurate personal data about you rectified
and, taking into account the purposes of the processing, to have any incomplete
personal data about you completed.
9.5 In some circumstances you have the right to the erasure of your personal
data without undue delay. Those circumstances include: the personal data are no
longer necessary in relation to the purposes for which they were collected or
otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have
been unlawfully processed. However, there are exclusions of the right to
erasure. The 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.
9.6 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.
9.7 You have the right to object to our processing of your personal data on
grounds relating to your particular 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.
9.8 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.
9.9 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 particular situation, unless the processing is necessary for
the performance of a task carried out for reasons of public interest.
9.10 To the extent that the legal basis for our processing of your personal
data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which
you are party or in order to take steps at your request prior to entering into
a contract, 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.
9.11 If you consider that our processing of your personal information infringes
data protection laws, you have a legal right to lodge a complaint with a
supervisory authority responsible for data protection. You may do so in the EU
member state of your habitual residence, your place of work or the place of the
alleged infringement.
9.12 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.
9.13 You may exercise any of your rights in relation to your personal data [by
written notice to us OR, in addition to the other methods specified in this
Section 9.
10. Third party websites
10.1 Our website includes hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies
and practices of third parties.
11. Personal data of children
11.1 Our website and services are targeted at persons over the age of 13.
11.2 If we have reason to believe that we hold personal data of a person under
that age in our databases, we will delete that personal data.
12. Updating information
12.1 Please let us know if the personal information that we hold about you
needs to be corrected or updated.
13. Acting as a data controller
13.1 In respect of your contact information, we act as a data controller and
have nominated a data processor to safeguard your information.
13.2 Insofar as we act as a data controller, our legal obligations as a data
controller are set out in the contract between us and the relevant data
processor.
14. Our details
14.1 This website is owned and operated by Faceguard Ltd.
14.2 We are registered in England and Wales under registration number 03406472
and our registered office is at 62-64
Northumbria Drive, Bristol BS9 4HW
14.3 Our principal place of business is at 62-64 Northumbria Drive, Bristol BS9 4HW
14.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to
time; or
(d) by email, using the email address published on our website from time to
time.
15. Representative within the European Union
15.1 Faceguard has a GDPR compliance Officer and you can contact them by
emailing GDPR@Faceguard.co.uk
