ABOUT THIS POLICY
Our full details are:
Mr Glenn Duff BEng(Hons) trading as Spera Computer Consultancy
Email address: firstname.lastname@example.org
Business website: https://www.speracc.com
Postal address: 75 The Causeway, Quedgeley, Gloucester. GL2 4LD.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would be grateful if you would contact us first if you do have a complaint so that we can try to resolve it with you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com.
WHAT DATA DO WE COLLECT ABOUT YOU
Personal data means any information capable of identifying a living person either in its own right or in combination with other data that is available. It does not include anonymised data. We may process certain types of personal data about you as follows:
This may include some or all of your title, first name, middle names, last name and username.
This may include some or all of your billing address, delivery address, work addresses, email addresses, skype addresses, WhatsApp phone number and telephone numbers.
This may include your bank account details from cheques received or BACS transfers received or made.
This may include details about payments between us and other details of purchases made by you whether through us or not.
This may include some or all of your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform, log files and other technology on the devices you use to access our website or services.
This may include information about how you use our website, products and services.
Marketing and Communications Data
This may include your preferences in receiving marketing communications from us and your communication preferences.
We may also process aggregated data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is if we reviewed your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
Sensitive/Special Category Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different potential methods including:
You may provide data by filling in forms on our website or by communicating with us by post, phone, e-mail, text, answer-phone, social media, face-to-face or otherwise, including when you:
– order our products and services;
– respond to our advertisements or invitations for products and services;
– provide feedback.
Automated technologies or interactions
Third parties or publicly available sources
We may receive (but not necessarily use) personal data about you from various third parties and public sources as set out below
– Technical Data from analytics providers such as Google based outside the EU
– Technical Data from IT Service Providers;
– Identity and Contact Data from publically available sources such as Internet Search Results
– Identity and Contact Data from publically available sources such as Social Media
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
– Where we need it to execute the contract between us.
– Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests according to our assessment of them.
– Where we need to comply with a legal or regulatory obligation.
– Where you have given consent to marketing communications or some other processing as defined on the consent form.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the lawful basis on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your data. Please email us at firstname.lastname@example.org if you need details about the specific lawful basis we are relying on to process your personal data where more than one option has been set out in the table below.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
|Purpose / Activity||Types of Personal Data||Lawful Bases for Processing|
|To respond to enquiries from a Potential Customer||- Identity Data|
- Contact Data
|To accept work tasks from Potential Customers and Actual Customers||- Identity Data|
- Contact Data
|Common tasks to complete our work tasks, including|
- Raising invoices
- Keeping business records
- Manage payments, fees and charges
|- Identity Data|
- Contact Data
- Transaction Data
- Financial Data
- Legal Obligation
|To manage our relationship with Actual Customers, including|
- Notifying customers about changes to our data protection policies
|- Identity Data|
- Contact Data
- Usage Data
- Legal Obligation
|To implement our Disaster Recovery strategy, including|
- Backing up Customer Records
- Backing up Business Accounts
|- Identity Data|
- Contact Data
- Transaction Data
- Financial Data
- Legal Obligation
- Legitimate Interest (to maintain business continuity)
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the lawful basis of processing.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above:
– Service providers who provide IT and system administration services.
– Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
– HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
None of our third party service providers are based outside the European Economic Area (EEA) so the processing of your personal data will not involve a transfer of data outside the EEA as far as we are aware.
If we did knowingly need to transfer your personal data out of the EEA, we would do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
– We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
– Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
– Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. Please email us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate physical and electronic security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including the use of encryption for backups and some communications.
In addition, we limit access to your personal data to those third parties who have a business need to access the data e.g. our IT providers. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Whenever possible, we will always choose UK-based companies with entirely UK-based servers.
If password access is required for certain parts of our website, you are responsible for keeping this password confidential.
Transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your Personal Data transmitted over the Internet although we use industry standard SSL encryption on all the pages on our website.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the business purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for about six years after they cease being customers for tax purposes.
When we receive enquiries from potential customers and until such time as we accept work tasks so that they become actual customers, the data retention period we employ is 4 weeks from the date of the last received communication from them.
In some circumstances you can ask us to delete your data: see below for further information.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
– Request access to your personal data.
– Request correction of your personal data.
– Request erasure of your personal data.
– Object to processing of your personal data.
– Request restriction of processing your personal data.
– Request transfer of your personal data.
– Right to withdraw consent.
For more information:
If you wish to exercise any of the rights set out above, please email us at email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
You can choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser.
You can choose to delete cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
Websites may place the following types of cookie on a device:
|Type of Cookie||Purpose|
|Strictly necessary cookies||These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.|
|Analytical/performance cookies||They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.|
|Functionality cookies||These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).|
|Targeting cookies||These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.|
Our website is a WordPress website and so WordPress and any plug-ins we might use at any time may place and access their own cookies on your computer. We may also use our own cookies to improve your experience of using the website and to improve our services but currently we do not do this. All cookies used by our website are used in accordance with current UK and EU Cookie Law.
Our Contact page uses a Google reCaptcha and Google may place common targeting cookies e.g. ‘NID’ on your device which may contain personal data. We do not control this. Please see .
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
CHANGES TO THIS POLICY
Version 1.0, 26 May 2018