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Privacy Policy

We are committed to safeguarding the privacy of our website visitors; this policy sets out how we will treat your personal information.


[Our website uses cookies. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.]


 

(1) Credit

 


We created this privacy policy using an SEQ Legal template available from www.website-law.co.uk. The templates available from SEQ Legal include a template saas agreement.


 

(2) What information do we collect?

 


We may collect, store and use the following kinds of personal information:


[(a) information about your computer and about your visits to and use of this website (including [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation ]


[(b) information relating to any transactions carried out between you and us on or in relation to this website, including information relating to any purchases you make of our

goods or services]


[(c) information that you provide to us for the purpose of registering with us]


[(d) information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters ]


[(e) any other information that you choose to send to us]


 

(3) Cookies

 


A cookie consists of information sent by a web server to a web browser, and stored by the browser. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.


We [may] use [both] ["session" cookies] [and "persistent" cookies] on the website.


[Session cookies will be deleted from your computer when you close your browser.] [Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.]


Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. For example, in Internet Explorer you can refuse all cookies by clicking "Tools", "Internet Options", "Privacy", and selecting "Block all cookies" using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites[, including this one].]


 

(4) Using your personal information

 


Personal information submitted to us via this website will be used for the purposes specified in this privacy policy or in relevant parts of the website.


We may use your personal information to:


[(a) administer the website;]


[(b) improve your browsing experience by personalising the website;]


[(c) enable your use of the services available on the website;]


[(d) send to you goods purchased via the website, and supply to you services purchased via the website;]


[(e) send statements and invoices to you, and collect payments from you;]


[(f) send you general (non-marketing) commercial communications;]


[(g) send you email notifications which you have specifically requested;]


[(h) send to you [our newsletter and other] marketing communications relating to our business [or the businesses of carefully-selected third parties]

which we think may be of interest to you by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time

if you no longer require marketing communications);]


[Where you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant to us.]


[We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.]


[All our website financial transactions are handled through our payment services provider, PayPal. You can review the PayPal privacy policy at www.paypal.com. We will share information with PayPal only to the extent necessary for the purposes of processing payments you make via our website and dealing with complaints and queries relating to such payments.]


 

(5) Disclosures

 


We may disclose information about you to [any of our employees, officers, agents, suppliers or subcontractors] insofar as reasonably necessary for the purposes as set out in this privacy policy.


In addition, we may disclose your personal information:


(a) to the extent that we are required to do so by law;


(b) in connection with any legal proceedings or prospective legal proceedings;


(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);


[(d) to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling; and]


[(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.]


Except as provided in this privacy policy, we will not provide your information to third parties.


 

(6) International data transfers

 


Personal information that you submit for publication on the website will be published on the internet and may be available, via the internet, around the world.

We cannot prevent the use or misuse of such information by others.


You expressly agree to such transfers of personal information.


 

(7) Security of your personal information

 


We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.


[We will store all the personal information you provide on our secure (password- and firewall- protected) servers.

All electronic transactions you make to or receive from us will be encrypted [using SSL technology].]


Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.


[You are responsible for keeping your password and user details confidential. We will not ask you for your password (except when you log in to the website).]


 

(8) Policy amendments

 


We may update this privacy policy from time-to-time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes.


[We may also notify you of changes to our privacy policy by email.]


 

(9) Your rights

 


You may instruct us to provide you with any personal information we hold about you.


We may withhold such personal information to the extent permitted by law.


You may instruct us not to process your personal information for marketing purposes by email at any time. 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.


 

(10) Third party websites

 


The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites.


 

(11) Updating information

 


Please let us know if the personal information which we hold about you needs to be corrected or updated.


 

(12) Contact

 


If you have any questions about this privacy policy or our treatment of your personal information,

please write to us by email to This email address is being protected from spambots. You need JavaScript enabled to view it. or by post to [OOOD , 2 Ashton Gate Road , Bristol BS3 1SZ ,UK ].


 



Bristol

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NOTE! This site uses cookies and similar technologies.

By continuing to use this website you express your consent to its use of cookies! Learn more

I understand

The EU cookie law (e-Privacy Directive)

The law which applies to how you use cookies and similar technologies for storing information on a user’s equipment such as their computer or mobile device changed on 26 May 2011.

We’ve answered some of your FAQs in a YouTube video, summarising how you can comply and the approach the ICO is taking to enforcement. (Playing YouTube videos sets a cookie.)

 

ICO guidance

Updated in May 2012, our cookies guidance sets out the changes to the cookies law and explains the steps you need to take to ensure you comply.

Download the ICO cookies guidance (pdf)

Our guidance includes additional information about implied consent:

  • Implied consent is a valid form of consent and can be used in the context of compliance with the revised rules on cookies.
  • If you are relying on implied consent you need to be satisfied that your users understand that their actions will result in cookies being set. Without this understanding you do not have their informed consent.
  • You should not rely on the fact that users might have read a privacy policy that is perhaps hard to find or difficult to understand.
  • In some circumstances, for example where you are collecting sensitive personal data such as health information, you might feel that explicit consent is more appropriate.

Find out more about the action we're taking on cookies

European data protection authorities opinion

In June 2012, European data protection authorities (as part of the Article 29 Working Party) adopted an opinion which clarifies that some cookie uses might be exempt from the requirement to gain consent:

  • Some cookies can be exempted from informed consent under certain conditions if they are not used for additional purposes. These cookies include cookies used to keep track of a user’s input when filling online forms or as a shopping cart, also known as session-id cookies, multimedia player session cookies and user interface customisation cookies, eg language preference cookies to remember the language selected by the user.
  • First party analytics cookies are not likely to create a privacy risk if websites provide clear information about the cookies to users and privacy safeguards, eg a user friendly mechanism to opt out from any data collection and where they ensure that identifiable information is anonymised.

Cookies and personal data

Regulation 6 covers the use of electronic communications networks to store information, eg using cookies, or gain access to information stored in the terminal equipment of a subscriber or user.

Although devices which process personal data give rise to greater privacy and security implications than those which process data from which the individual cannot be identified, the Regulations apply to all uses of such devices, not just those involving the processing of personal data.

Where the use of a cookie type device does involve the processing of personal data, service providers will need to make sure they comply with the additional requirements of the Data Protection Act 1998 (the Act). This includes the requirements of the third data protection principle which states that data controllers must not process personal data that is excessive. Where personal data is collected, the data controller should consider the extent to which that data can be effectively processed anonymously. This is likely to be particularly relevant where the data is to be processed for a purpose other than the provision of the service directly requested by the user, for example, counting visitors to a website.

Confidentiality of communications and spyware

It should be remembered that the intention behind this Regulation is also to reflect concerns about the use of covert surveillance mechanisms online. Here, we are not referring to the collection of data in the context of conducting legitimate business online but the fact that so-called spyware can enter a terminal without the knowledge of the subscriber or user to gain access to information, store information or trace the activities of the user and that such activities often have a criminal purpose behind them.

Information to be provided

Cookies or similar devices must not be used unless the subscriber or user of the relevant terminal equipment:

(a) is provided with clear and comprehensive information about the purposes of the storage of, or access to, that information; and

(b) has given his or her consent.

The Regulations are not prescriptive about the sort of information that should be provided, but the text should be sufficiently full and intelligible to allow individuals to clearly understand the potential consequences of allowing storage and access to the information collected by the device should they wish to do so. This is comparable with the transparency requirements of the first data protection principle.

The Regulations state that once a person has used such a device to store or access data in the terminal equipment of a user or subscriber, that person will not be required to provide the information described and obtain consent (and discussed above) on subsequent occasions, as long as they met these requirements initially. Although the Regulations do not require the relevant information to be provided on each occasion, they do not prevent this.

Responsibility for providing the information and obtaining consent

The Regulations do not define who should be responsible for providing the information and obtaining consent. Where a person operates an online service and any use of a cookie type device will be for their purposes only, it is clear that that person will be responsible for complying with this Regulation.

Exemptions from the right to refuse a cookie

The Regulations specify that service providers should not have to provide the information and obtain consent where that device is to be used:

  • for the sole purpose of carrying out or facilitating the transmission of a communication over an electronic communications network; or
  • where such storage or access is strictly necessary to provide an information society service requested by the subscriber or user.

In defining an 'information society service' the Electronic Commerce (EC Directive) Regulations 2002 refer to 'any service normally provided for remuneration, at a distance, by means of electronic equipment for the processing (including digital compression) and storage of data, and at the individual request of a recipient of a service'.

The term 'strictly necessary' means that such storage of or access to information should be essential, rather than reasonably necessary, for this exemption to apply. However, it will also be restricted to what is essential to provide the service requested by the user, rather than what might be essential for any other uses the service provider might wish to make of that data. It will also include what is required to comply with any other legislation the service provider might be subject to, for example, the security requirements of the seventh data protection principle.

Where the use of a cookie type device is deemed 'important' rather than 'strictly necessary', those collecting the information are still obliged to provide information about the device to the potential service recipient and obtain consent.

Wishes of subscribers and users

Regulation 6 states that consent for the cookie type device should be obtained from the subscriber or user but it does not specify whose wishes should take precedence if they are different.

There may well be cases where a subscriber, for example, an employer, provides an employee with a terminal at work along with access to certain services to carry out a particular task, where to effectively complete the task depends on using a cookie type device. In these cases, it would not seem unreasonable for the employer’s wishes to take precedence.

However, it also seems likely that there will be circumstances where a user’s wish should take precedence. To continue the above example, an employer’s wish to accept such a device should not take precedence where this will involve the unwarranted collection of personal data of that employee.