This notice was updated on 23 January 2019
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, including:
We need to collect and process these types of Personal Information in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide you with the requested Services.
We and our service providers may collect Personal Information in a variety of ways, including:
We and our service providers use Personal Information for legitimate business purposes, including the following:
Your Personal Information may be disclosed:
We may also use and disclose your Personal Information as we believe to be necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
In addition, we have a legitimate interest in using, disclosing or transferring your information to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
Collection of Other Information:
We and our service providers may collect Other Information in a variety of ways, including:
Uses and Disclosures of Other Information;
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organisations, such as Facebook, Apple, Google, Microsoft or any other developer, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organisations through or in connection with our Social Media Pages.
We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services, based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. To do so, these companies may place or recognise a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognise you across the devices you use, such as a mobile phone and a laptop.
We seek to use reasonable organisational, technical and administrative measures designed to protect Personal Information within our organisation. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Your choices regarding our use and disclosure of your Personal Information:
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, change or suppress your Personal Information:
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we will only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
We will retain your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Services to you; (ii) when we have legal obligation to which we are subject; or (iii) as advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under eighteen (18).
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of the UK. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
Additional information regarding the EEA: Some of the non-EEA countries are recognised by the European Commission as providing an adequate level of data protection according to EEA standards. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information.
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g. National Insurance numbers, information related to racial or ethnic origin, political opinions, religious beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.