Data and Privacy Policy

This Privacy Policy sets out how we, PW New Media (a trading Name of Mr Paul Ian Woodland), collect, store and use information about you when you use or interact with our websites, pwnewmedia.com, liquidsix.com, their subdomains and associated sites (collectively known as our website) and where we otherwise obtain or collect information about you.

This Privacy Policy is effective from 1st January 2021.

As we are located in the United Kingdom, this document refers to the UK General Data Protection Regulation (UK GDPR) and is covered by the Data Protection Act 2018.

This policy covers our standard business practices and basic services, including account information. However, to simplify the document, and so that our customers can see more easily what applies to them, it does not cover extra data stored with us if you hold web hosting services with us, including domain registrations, SSL certificates and any other associated services. This is covered in a separate document, the "Web Hosting Data Policy". If you purchase web hosting or related services from us, you will be asked to agree to the web hosting data policy separately.

Contents

1. Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: Paul Woodland

  • How we collect or obtain information about you:
    • when you provide it to us (e.g. by contacting us, registering for an account on our website, registering for our newsletter or ordering services from us),
    • from your use of our website, including using cookies, and
    • occasionally from third parties.

  • Information we collect: name, contact details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable) and VAT number (if applicable).

  • How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyse your use of our website and in connection with our legal rights and obligations.

  • Disclosure of your information to third parties: only to the extent necessary to run our business, to fulfil any contracts we enter into with you and where required by law or to enforce our legal rights.

  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No

  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled 8. How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled 8. How long we retain your information.

  • How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.

  • Use of cookies: we use cookies on our website including essential and functional cookies. For more information, please visit our cookies policy here: "Cookies Policy"

  • Transfers of your information outside the United Kingdom and/or the European Economic Area: in certain circumstances we transfer your information outside of the UK and/or European Economic Area, including to the following countries: United States of America, New Zealand. Where we do so, we will ensure appropriate safeguards are in place.

  • Use of automated decision making and profiling: we do not use automated decision making or profiling.

  • Your rights in relation to your information:
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • to complain to a supervisory authority

  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as 'sensitive personal information'. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled 14. Sensitive Personal Information.

2. Our details

The data controller in respect of our website and services is Paul Woodland of PW New Media. You can contact the data controller by writing to PO Box 5015, Worthing, West Sussex, BN11 9DB or sending an email to services@pwnewmedia.com.

If you have any questions about this Privacy Policy, please contact the data controller.

For residents of the EEA, the data controller's representative is Adam Brogden, Instant EU GDPR Representative Ltd. You can contact the data controller's representative by using the web based form available at https:mr-paul-ian-woodland-ta-pw-new-media.gdprlocal.com/eu, writing to "INSTANT EU GDPR REPRESENTATIVE LIMITED, Office 2, 12A Lower Main Street, Lucan Co. Dublin, K78 X5P8. Ireland", sending an email to contact@gdprlocal.com or calling on + 353 15 549 700. Whilst we are obliged to provide details of a represenative within the EEA, a quicker response to your query or data request will be received if you contact us directly using the details at the beginning of this section.

3. Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled 7. Disclosure and additional uses of your information.

3.1. Web server log information

We use our own server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Our server is located in the United Kingdom.

Use of website server log information for IT security purposes

We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the UK General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.

Use of website server log information to analyse website use and improve our website

We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interest: improving our website for our website users and getting to know our website users' preferences so our website can better meet their needs and desires.

3.2. Cookies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential, functional. For further information on how we use cookies, please see our cookies policy which is available here: "Cookies Policy".

You can reject some or all of the cookies we use on or via our website by changing your browser settings or by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

4. Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled 7. Disclosure and additional uses of your information.

4.1. Email

When you send an email to any of our email addresses we collect your email address and any other information you provide in that email (such as your name, telephone number, the information contained in any signature block in your email and information located in the email headers).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the UK General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use our own email servers to store some emails you send us, and also use a third party email provider to store some emails you send us. Our third party email provider is Microsoft, and the server is located in the United Kingdom.

4.2. Contact form and Helpdesk

When you contact us using our contact form or web based helpdesk, we collect your name, email address and IP address. We also collect any other information you provide to us when you complete the contact form.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the UK General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Messages you send us via our contact form will be stored within the European Economic Area on our servers in the United Kingdom. Some messages may be stored on our third party email server. Our third party email provider is Microsoft, located in United Kingdom.

4.3. Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.

We may record phone calls in some situations, but you will be informed prior to this happening.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the UK General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider (Sipgate) which is located in Germany. Their privacy policy is available here .

Information about your phone call will be stored by our third party telephone service provider within the European Economic Area.

4.4. Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the UK General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

5. Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled 7. Disclosure and additional uses of your information.

5.1. E-Newsletter

When you sign up for our e-newsletter or opt to receive news, offers and updates about our services from us by entering their name and email address and clicking subscribe or ticking a box at registration indicating that you would like to receive our e-newsletter, we collect your name, email address and IP address.

Legal basis for processing: your consent (Article 6(1)(a) of the UK General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

Information you submit to subscribe for our e-newsletter will be stored within the European Economic Area on our servers in the United Kingdom.

5.2. Registering on our website

When you register and create an account on our website, we collect the following information: name, email address, IP address and any other information you provide to us when you complete the registration form, including any optional information, such as mobile telephone number, other telephone numbers, Facebook account information and Twitter account information.

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing: your consent (Article 6(1)(a) of the UK General Data Protection Regulation).
Details: You consent to us processing this information by registering on our website, which you can withdraw your consent for at any time.

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored within the European Economic Area on our servers in the United Kingdom.

6. Information we collect when you place an order

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled 7. Disclosure and additional uses of your information

6.1. Information collected when you place an order

Mandatory information

When you place an order for services on our website, we collect your name, email address, billing address, organisation type, company/trading name (if applicable), VAT number (if applicable) and IP Address.

If you do not provide this information, you will not be able to purchase services from us on our website or enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the UK General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the UK General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions

Optional information

We also collect optional information from you, such as your phone number and information about how you heard about us. We also ask you if you would like to receive marketing communications from us. For further information, see 'E-Newsletter' above.

Legal basis for processing: your consent (Article 6(1)(a) of the UK General Data Protection Regulation).
Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.

6.2. Processing your payment

After you place an order on our website you will need to make payment for the services you have ordered. In order to process your payment we use third party payment processors, including Stripe, GoCardless and PayPal. Your payment will be processed by the third party payment processor from the list that you choose to process your payment.

The third party payment processor you choose to process your payment collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via the following link(s): Stripe Privacy Policy , GoCardless Privacy Policy , PayPal Privacy Policy

Transfer and storage of your information

Stripe is located in the United States. Information relating to the processing of your payment is stored on our third party payment processor's servers, with adequate protection of personal data, certified to the EU-U.S. and Swiss-U.S. Privacy Shield Framework.

GoCardless is located in the United Kingdom. Information relating to the processing of your payment is stored within the United Kingdom on our third party payment processor's servers.

PayPal is located in Luxemburg. Information relating to the processing of your payment is stored outside of the United Kingdom and within the European Economic Area on our third party payment processor's servers.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the UK General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

6.3. Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

We do receive information about you from third parties. The third parties from which we receive information about you will generally include our payment processors, Stripe, GoCardless and PayPal.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the UK General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the UK General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

6.4. Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, media publications, social media and websites (including your own website if you have one).

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the UK General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.

7. Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

7.1. Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following

  • Telephone provider(s), including Sipgate and MessageBird. Their privacy policies are available here: Sipgate Privacy Policy , MessageBird Privacy Policy . These service providers are located in Germany and the Netherlands respectively.

  • Email provider(s), including Microsoft. Their privacy policy is available here: Microsoft Privacy Policy . This service provider is located in the United Kingdom.

  • Payment processor(s), including Stripe, GoCardless and PayPal. Their privacy policies are available here: Stripe Privacy Policy , GoCardless Privacy Policy , PayPal Privacy Policy . These service providers are located in the United States (Stripe), Luxemburg (PayPal) and the United Kingdom (GoCardless).

  • Accounting software provider(s), including Xero. Their privacy policy is available here: Xero Privacy Policy . This service provider is located in New Zealand.

  • IP Address information provider(s), including MaxMind. Their privacy policy is available here: MaxMind Privacy Policy . This service provider is located in the United States of America.

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of some of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the UK General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

7.2. Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accounting software providers, advisors and IP address information providers. Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.

Accounting Software Providers

We share information with our accounting software providers for tax purposes. For example, we share invoices we issue and receive with our providers for the purpose of completing tax returns and our end of year accounts.

Our accounting software providers are Xero. Their privacy policy is available here: Xero Privacy Policy . They are located in New Zealand.

Advisors

Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

Such parties would be appointed if and when they are needed, and this privacy policy updated accordingly.

IP Address Information Providers

We share your IP address (with no other identifying information) with our IP address information providers to identify the geographic location that you are accessing our services from.

Our IP address information providers are MaxMind. Their privacy policy is available here: here: MaxMind Privacy Policy . They are located in the United States of America.

Business Sale

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

7.3. Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the UK General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom's legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the UK General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom's legal framework, we have a legitimate interest in complying with these obligations.

8. How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

8.1. Retention periods

Server log information

We retain information on our server logs for no longer than 13 months from the end of the calendar month in which they are created.

Order information

When you place an order for services, we retain that information for six years following the end of the financial year in which you last placed an order using that billing account, to allow you to view your historical information and in accordance with our legal obligation to keep records for tax purposes.

Correspondence and enquiries

When you make an enquiry or correspond with us for any reason, whether by email, via our contact form, helpdesk or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry (or, if your enquiry related to an ongoing contract, for as long as this contracted service remains active, for the purposes of assisting you further in the future). The information will then be deleted within 13 months of the end of the calendar year in which it was received, or it can be deleted earlier upon your request.

Newsletter

We retain the information you used to sign up for our newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Your login information

We retain the information you used to register with for as long as you keep your account with us open. It is then kept for no more than 21 days after you close your account, or if we decide to cancel our services, whichever comes earlier.

8.2. Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

9. How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website;
  • only transferring your information via closed system or encrypted data transfers;

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

10. Transfers of your information outside the United Kingdom and/or European Economic Area

Your information will be transferred and stored outside the United Kingdom and/or the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the UK and/or the EEA, or to an international organisation, in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

Accounting Software Providers

Information you submit to us for invoicing purposes is transferred outside the UK and the EEA and stored on our accounting software provider's servers. Our accounting software provider is Xero. You can access their privacy policy here .

Country of storage: New Zealand. This country is subject to an adequacy decision by the European Commission.

Safeguard(s) used: All information is transmitted securely using Secure Sockets Layer (SSL) technologies.

IP Address Location Providers

Your IP address (with no other identifying information) may be transmitted to our provider in order to look up geographical location information. Our IP address location provider is MaxMind. You can access their privacy policy here .

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: All information is transmitted securely using Secure Sockets Layer (SSL) technologies and contains no personal information other than the IP address itself.

11. Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to "PO Box 5015, Worthing, West Sussex, BN11 9DB" or contacting us via our contact page:

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information ("right to erasure");
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled 13. Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

In accordance with Article 77 of the UK General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, which for the purposes of the UK, is the Information Commissioner's Office (ICO), the contact details of which are available here

If you are resident within the EEA, you also have the right to lodge a complaint with the supervisory authority in your country of residence.

Further information on your rights in relation to your personal data as an individual

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO's website:

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the UK General Data Protection Regulation, which is available here: http:ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

12. Making it easy to exercise your rights and update your information

The rights described in the previous section can always be exercised in the manner described, however we also offer easy and automated methods of exercising some of these rights, for your convenience. These include:

12.1. "Right to Erasure" for your data

There are many types of data that you can remove by closing your account, or parts of it, if you no longer need them. To do this, login to your account with us at the Account Area, click on "Login Details" and then follow the link to close your account or cancel services. If you do not have an account that allows you to login to this area, please contact us instead to request the closure.

12.2. Withdraw your consent for processing your data

You can withdraw your consent by closing your account, or parts of it, if you no longer need them. To do this, login to your account with us at the Account Area, click on "Login Details" and then follow the link to close your account or cancel services. If you do not have an account that allows you to login to this area, please contact us instead to request the closure.

12.3. Viewing the data we hold, or updating it

There are many types of data that you can view and manage from your account area. To do this, login to your account with us at the Account Area and use the available to links to browse and update the information. If you do not have an account that allows you to login to this area, please contact us instead to request the available data.

12.4. Withdraw your consent for marketing messages

You can withdraw your consent for marketing messages, without affecting any other data that we hold, by unsubscribing. You can do this using our automated management system or by contacting us to request that we remove you from marketing messages.

13. Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in by writing to "PO Box 5015, Worthing, West Sussex, BN11 9DB" contacting us via our contact page:

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests; and

  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;

  • managing your newsletter subscriptions via the automated management page on our website.

  • contacting us via our website contact page, asking that we stop sending you marketing communications or by including the words "OPT OUT".

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled "How to accept or reject cookies"" in our cookies policy, which is available here: Cookie Policy

14. Sensitive Personal Information

"Sensitive personal information" is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person's sex life or sexual orientation.

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the UK General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

15. Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time for many reasons, including changes in the law and changes in our suppliers and processes.

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

16. Children's Privacy

Because we care about the safety and privacy of children online, we comply with the Children's Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 16. The website is not intended to solicit information of any kind from persons under the age of 16.

It is possible that we could receive information pertaining to persons under the age of 16 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 16, please do so by contacting us via our contact page.

17. California Do Not Track Disclosures

"Do Not Track" is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: Cookie Policy.

18. Copyright, credit and logo

This Privacy Policy is based on a General Data Protection Regulation (Regulation (EU) 2016/769) (GDPR) compliant template provided by GDPR Privacy Policy. For further information, please visit gdprprivacypolicy.org .

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

Where we display the GDPR Privacy Policy logo on our website, this is used to indicate that we have adopted a privacy policy template provided by GDPR Privacy Policy as the basis for this Privacy Policy.

Version #3, applies from 01 January 2021