Issue 01 dated 18th May 2018
What Is The Purpose Of This Document?
Our full details are:
Adlaser Profiles Ltd
Diane Thorpe – firstname.lastname@example.org
Unit 16 Woodman Farm, Curdridge Lane, Curdridge, Southampton SO32 2BH
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third Party Links
Our website does not include links to third-party websites.
Data Protection Principles
We will comply with data protection law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name
- Contact Data includes business address, email address and telephone numbers
- Transaction Data includes details of products and services you have purchased from us.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We do not collect, use or share statistical or demographic data for any purpose.
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
Failure To Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
Methods Of Personal Data Collection
We use different methods to collect data from and about you, including through:
Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Enquire about a Goods or Service
- Give us some feedback.
Use Of Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract that we are about to enter into with you, or have entered into with you.
- Where we need to comply with a legal, or regulatory obligation.
- Where it is necessary for both your and our legitimate interests where fundamental rights do not override those interests.
Generally, we do not rely on consent as a legal basis for processing your personal data.
Purposes For Which We Will Use Your Personal Data
We have set out at Annex A to this Policy , in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional Offers From Us
We may use your Identity/Contact Details for marketing purposes however we do not provide promotional offers.
You will receive marketing communications from us if you have requested information from us and where you have not opted out of receiving marketing.
We will not share your personal data with any company outside of Adlaser Profiles Ltd for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures Of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out above.
- Internal Third Parties
- External Third Parties
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (EEA).
We limit access to your personal data to those employees and third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Data Retention Period:
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Once you are no longer an employee or customer of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Rights Of Access, Correction, Erasure And Restriction
Your legal rights:
Under certain circumstances you have rights under data protection laws in relation to your personal data as follows:
(i) To request access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(ii) To request the correction of personal data that we hold about you.
This enables you to have any incomplete or inaccurate data we hold about you corrected, however we may need to verify the accuracy of the new data that you provide to us
(iii) To request erasure of your personal data.
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed information unlawfully or where we are required to erase your personal data to comply with local law.
Please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(iv) To object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(v) To request the restriction of processing of your persona data.
This enables you to ask us to suspend the processing of personal data in the following scenarios:
(a) If you want us to establish the data’s accuracy;
(b) Where our use of the data is unlawful but you do not want us to erase it;
(c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
(d) Where you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(vi) To request the transfer of your personal data to you or a third party.
We will provide you or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact email@example.com in writing at Unit 16 Woodmans Farm, Curdridge Lane, Curdridge, Southampton SO32 2BH
No Fee Usually Required
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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access the data (or to exercise any of your other rights). This is an appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Time Limit To Respond
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.
Right To Withdraw Consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
“Comply with a legal or regulatory obligation” means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties:
External Third Parties:
Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.