Privacy Policy

1.       Introduction

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    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

2.       Credit

2.1    This document was created using a template from SEQ Legal (https://seqlegal.com/free-legal-documents/privacy-policy).

You must retain the above credit. Use of this document without the credit is an infringement of copyright. However, you can purchase from us an equivalent document that does not include the credit.

3.       How we use your personal data

3.1    In this Section 3 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.

3.11  In addition to the specific purposes for which we may process your personal data set out in this Section 3, 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.

4.       Providing your personal data to others

4.1    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)].

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)    [usage data will be retained for a minimum period of 1 year following the date of collection, and for a maximum period of 6 years following that date];

(b)    [account data will be retained for a minimum period of 1 year following the date of closure of the relevant account, and for a maximum period of 6 years following that date];

(c)    [publication data will be retained for a minimum period of 1 year following the date when the relevant publication ceases to be published on our website or through our services, and for a maximum period of 6 years following that date];

(d)    [enquiry data will be retained for a minimum period of 1 year following the date of the enquiry, and for a maximum period of 6 years following that date];

(e)    [transaction data will be retained for a minimum period of 1 year following the date of the transaction, and for a maximum period of 6 years following that date];

(f)    [notification data will be retained for a minimum period of 1 year following the date that we are instructed to cease sending the notifications, and for a maximum period of 6 years following that date (providing that we will retain notification data insofar as necessary to fulfil any request you make to actively suppress notifications)]; and

6.4    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.       Your rights

7.1    In this Section 7, we have listed the rights that you have under data protection law.

7.2    Your principal rights under data protection law are:

(a)    the right to access - you can ask for copies of your personal data;

(b)    the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure - you can ask us to erase your personal data;

(d)    the right to restrict processing - you can ask use to restrict the processing of your personal data;

(e)    the right to object to processing - you can object to the processing of your personal data;

(f)    the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g)    the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h)    the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

7.3    These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.

7.4    You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].

8.       About cookies

8.1    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.

10.    Cookies used by our service providers

10.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.    Managing cookies

11.1  Most browsers allow you to refuse to 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:

(a)    https://support.google.com/chrome/answer/95647 (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).


11.2  Blocking all cookies will have a negative impact upon the usability of many websites.

12.    Amendments

12.1  We may update this policy from time to time by publishing a new version on our website.

13.    Our details

13.1  This website is owned and operated by Jonathan Warren CeMAP.

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